On 19 July 2024 the Rulebook on the manner of entry, updating, verification and access to data from the Register of Beneficial Owners was published in the Official Gazette of Montenegro, No. 068/24.
We have previously written about the obligations of registering beneficial owners. In this text we will focus exclusively on the novelties defined by the Rulebook.
1. Person Authorized to Enter Data
Entities required by law to register beneficial owners designate a person authorized to enter data into the Register.
Requirements for the authorized person:
- Must have residence or permanent stay in Montenegro
- May be an employee, representative or proxy of the entity
Tasks of the Authorized Person
- Enters data
- Updates
- Verifies
- Confirms data
In accordance with the Law on the Prevention of Money Laundering and Terrorism Financing — using Form 1 (an integral part of the Rulebook).
2. Scanned Documentation
When entering data into the Register, the authorized person uploads the scanned authorization (Form 1) and scanned documentation:
a) For entities with a complex ownership structure
Documentation under Article 45, paragraph 2, points 2 and 3 of the Law:
- Note on the existence of a complex ownership structure
- Graphic presentation of the ownership structure
- Extract from the CRPS or other register
b) ID document of the beneficial owner
- For foreign owners — additional documentation proving the data entered (in accordance with the Law)
3. Verification, Confirmation and Data Access
Obligations of the Authorized Person
- Verify the accuracy of data in the Register via the online application
- If differences are noticed — update without delay
- Confirmation of accuracy is done with a qualified electronic signature
Data Access
Competent authorities, the financial intelligence unit, obligors and other legal and natural persons access the data using electronic identification means of a high security level.
In case of access problems — data is provided via a request or in the form of an extract from the Register.
Need help with entering, updating or verifying data in the Register of Beneficial Owners? Contact Finance Plus.
