Spain: Beneficial Ownership Regime Now in Force

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Spain’s Ministerial Order 319/2018 was issued on 21 March, requiring Spanish non-listed companies to disclose their ultimate beneficial owners to the Companies Registry, and to keep the information updated.

Companies with an indirect ultimate beneficial owner must also identify the legal persons that intervene in the chain of control of the Spanish company.

The Order implements part of the EU Fourth Anti-Money Laundering Directive, but Spain has yet to fully implement the Directive’s other provisions – almost a year after its deadline for doing so.