Earlier this year, DLA Piper provided a multi-jurisdictional overview of the implementation of the UBO register in several EEA jurisdictions, including the Netherlands, the United Kingdom, France and Germany. Furthermore, DLA Piper Netherlands submitted some critical remarks as a response to the Dutch draft legislative proposal for implementation of the UBO register.
According to the European fourth anti-money laundering directive the UBO register should have been implemented by 26 June 2017. During the aforementioned publications, we were familiar with a possible delay until January 2018. However, it now seems that also this last deadline will not be met: State Secretary Wiebes announced last Tuesday that the concept legislative proposal will only be submitted to the Second Chamber (de Tweede Kamer) in the beginning of 2018. It is now expected that the UBO register will be operative from the summer of 2018.