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UBO Register of Trusts and of similar legal arrangements Alert 2, 2021

Cyprus implements Beneficial Ownership Register for trusts and similar legal arrangements

Further to the introduction of the register of Beneficial Owners (BOs) for companies, on the 18 June 2021 Cyprus has introduced a similar register for BOs of Trusts and other similar legal arrangements (the “Trust Register”) to be kept electronically by the Cyprus Securities and Exchanges Commission (CySEC) which is the supervisory authority for the implementation and operation of the Trust Register.

The Trust Register was implemented through CySEC’s Directive for the prevention and suppression of money laundering and terrorist financing (register of beneficial owners of express trusts and similar legal arrangements) (the “Directive”) which provides information and guidance in relation to the registration of express trusts and similar legal arrangements in the Trust Register.

The Directive applies for express trusts which are defined as trusts created expressly by a settlor at his own will. Trusts arising by operation of law as well as trusts for which the settlor shows no clear intention for their creation are not considered to be express trusts.

Registration of an express trust should take place in cases where:

  1. the trustee is located or residing in the Republic of Cyprus; or
  2. the trustee, which is located or residing outside EU, establishes a business relationship or acquires immovable property in Cyprus on behalf of the express trust.

Information to be submitted

The following information must be submitted for registration:

For the trusts and other similar legal arrangements

  • Name of the trust
  • Country and date of establishment
  • Applicable law
  • Termination date (if applicable)
  • Country in which the trustee is established or resides and details of his address
  • In case the trustee resides outside the EU and establishes a business relationship on behalf of the trust in Cyprus, the date of commencement of the business relationship, the name of the person with whom such relationship is established together with the document which governs such a relationship
  • In case the trustee resides outside the EU and acquires immovable property on behalf of the “Stated” (expressed) trust in Cyprus, the registration number and address of the immovable property together with the title deed of the property
  • Any other information and/or supporting documentation requested by CySEC for identification purposes

BO/s (trustee, settlor, protector, beneficiaries)

  • Name, surname and father’s name
  • Date and place of birth
  • Nationality/ies
  • Residential Address
  • Type, number and country of issuance of identification document
  • Date of death (where applicable)
  • Date on which the person became beneficial owner
  • The nature and extent of the rights which are directly or indirectly held by the UBO
  • The role of the UBO in the trust or in a similar legal arrangement
  • Any other information and/or supporting documentation requested by CySEC for identification purposes

In case the Trust has one or more classes of beneficiaries, the following information should also be provided:

  • Description of the class of beneficiaries and its members
  • the nature and extent of the rights of each class of beneficiaries

Deadlines and Charges

A six-month period has been granted for existing trusts to be registered.

For new trusts falling under either of the two cases, as well as for any changes in the information submitted to the Trust Register for trusts already registered, there is a time limit of 15 days from the date of appointment of the trustee or the date on which such changes were effected.

CySEC has set a scale of charges for registration and renewal of registration of trusts as well as for retrieving information.

Eligible persons/authorities for having access in the UBO trust register

Eligible for having access without any charge to the information entered in the Trust Register will be the trustees and or any other equivalent person who has entered such information thereinto, as well as other competent authorities like the Unit for Combating Money Laundering and Terrorist Financing, the police, the Customs’ Department, and the Tax Department. Furthermore, any person or organization who may demonstrate a legitimate interest and who provides sufficient evidence in this respect , may have access to such information under a fee if the relevant application submitted to CySEC is approved. The procedure is set as follows: CySEC acknowledges with the trustees and or the equivalent person of the receipt of an application from a certain person/authority and the fact that they have initially established that indeed such a person or authority has a legitimate interest. If the trustees do not file written representations within 10 days as of the date it has received CySEC’s acknowledgment, then such a person and or authority will be given access to the information kept in the Trust Register.