We would like to inform you that Act LIII. of 2017. on the Prevention of Money Laundering and
Terrorism (hereinafter: ‘PMT’) contains new mandatory procedures for accountants. In line with the
instructions we are required to record the details of our clients’ final beneficial owner (as a private
person).
Beneficial owner’s definition by PMT:
· natural person(s) who ultimately owns or controls the legal entity through direct or indirect
ownership of minimum 25% of the shares or voting rights in the legal entity (even through
close relatives or other legal entities), or ultimately controls the entity in any other way.
· natural person who exercises dominant influence, which means having the power to appoint
or dismiss majority of senior management or members of supervisory board (regardless of
ownership percentage), or based on an agreement with other shareholders they vote
identically or the other shareholders exercise their voting rights through that natural person
(given that they have more than 50% of the voting rights)
· in the lack of natural person(s) mentioned above the representative (e.g. managing director)
of the company,
· in certain cases, natural person, on whose behalf a transactions or activity is being conducted,
or ultimately controls another natural person activity in any other way.
We also need to record if the beneficial owner is a politically exposed person, or a family member of a
politically exposed person, or known to be a close associate of a politically exposed person. The details
of the beneficial owner shall be uploaded to a central database in every EU country.
Based on the abovementioned rules we ask you to be prepared for our colleagues’ queries in advance.
We draw your attention to that if there is any change in the previously recorded data or the data in
relation to the beneficial owner, you have to inform us within 5 working days in writing.
