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Pursuant to art. 23quater of Law n. 92/2008 of San Marino Law, legal persons (and foreign companies with the authorization referred to in article 3 of Delegated Decree n. 50/2024) shall communicate to a specific register the information concerning the natural persons who are the beneficial owners.
Following the amendments made to Law no. 92/2008 and to Delegated Decree no. 154/2023, we read in a notification from the Financial Information Agency that “from June 29, 2024, the Register of Beneficial Ownership is managed by the AIF”.
Therefore, the register can now be accessed on the PA portal through a new service called “RegTE (Register of Beneficial Ownership of Legal Entities)”.
With regard to the obligations required by law, the Financial Information Authority – in addition to recalling the provisions of art. 22 bis, paragraphs 2, 3 and 4 and art. 22 bis. 23 quater of Law no. 92/2008 – makes available on its website:
a) AIF Circular No. 001 of 29 July 2024 on the Regulation of the Register of Beneficial Ownership, which explains the obligations regarding communication and consultation obligations;
b) An operations manual for the beneficial ownership register which describes the procedures for accessing the relevant register and details the practices relating thereto.
It is important to point out here that, although the communication requirements remain the same, an obligation to annually confirm the data transmitted has also been introduced, by “confirming” the data already in the register, if there is no change in the beneficiary ownership. For associations and other bodies with legal personality, an automatic information communication mechanism has been introduced, as described in the notification referred to in a), taking into account the low risk of recent national anti-money laundering and terrorist financing risk assessments.
The AIF also provides an email address (regte@aif.sm) to which questions regarding relevant obligations and any procedural issues may be sent.
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