Clients Alert – Disclosure Requirements for Ultimate Beneficial Shareholders
On March 8th, 2020, the Minister of Supply and Internal Trade issued Ministerial Decree no. 41 (“Decree”) to introduce new Articles to the Executive Regulations of the Commercial Register Law no. 43/1976. The Decree imposes mandatory disclosure requirements on companies to reveal the ultimate beneficial Egyptian/Foreign shareholders (“Beneficiaries”) through maintaining a register that contains certain information of such Beneficiaries (“Register”). The Register must be duly updated in case of change of direct or indirect ownership structure.
The Decree necessitates that the following information of the Beneficiaries (i.e. their names, personal information, Nationality, National ID/Passport for foreigners) previously listed in the Register to be reflected in the companies’ Commercial Register. A new column to be inserted by the relevant Authority to the current register form to fulfill such requirements, which means that such information will be available to the public domain.
The Decree classifies the required information as material information required for registration of companies or annotation in commercial registers. In addition, companies are required to maintain the Register during the entire term of their operations and for a period of five (5) years after the companies cease operations or in the case of de-registration from the commercial register.
The Decree is entered into force as of March 9th, 2020.
If you have any questions, feel free to contact: