It has come to our attention that the MBR is taking an increased interest in ensuring that locally registered companies have various records required by the Companies Act (CA) to be in place and up to date.
Some of the documents being requested include (but are not limited to):
– Minutes of all shareholders’ and Directors’ meetings;
– Register of members (inclusive of references to nominee shareholding, pledged shares /securities;
– Share warrants and certificates;
– Register of transfers;
We are also becoming aware that the MBR has set up a Compliance Department tasked with carrying out inspections wherein they require additional documents that the CA requires to be held at the company’s registered office such as (but not limited to) :
– An organogram / group structure detailing all layers of beneficial ownership (BO) interest
– The Register of all Ultimate BOs
– Overview of the business entity and the nature of activity
Letters issued by the MBR seen by us requested the inspection of documents within 7 days subject to a penalty of Eur 10,000 “without further notice” in case of default.
We would strongly recommend you review your company’s records to ensure that you are in compliance to avoid any last minute reactions to such letters.