Since 2017 Uruguayan companies and other entities with a presence in Uruguay must report their ultimate beneficiaries and holders of registered equity interests, along with their full ownership chain, to the Central Bank of Uruguay (BCU). Under current regulations, compliance control rests with the Corporate Oversight Authority (AIN).
In addition to identifying and informing the BCU about their holders and ultimate beneficiaries, all such entities must keep records and supporting documentation provided for identification purposes. This information must be sufficient to permit reconstruction of the ultimate beneficiary’s identity and the chain of ownership. Finally, the rule also establishes that entities must implement procedures for identifying their ultimate beneficiaries, applicable for the current identification as well as each change. The procedures must be duly documented.
Thus, in compliance with its oversight duties, the AIN recently began to control different entities, requiring appearance of their representatives at its offices.
Based on experience to date, the AIN has requested the presence of a representative of the obligated entity (accredited as such by notarial certification) at AIN offices with certain documentation specifically indicated by the agency in each notification
The verification procedure usually consists of an interview with the representative in order to determine due compliance with these regulations.
FERRERE has organized a specialized team to assist clients in reviewing due compliance with legal obligations, as well as the documentation submitted, and in handling the different stages for verification at the National Oversight Authority.