How to draw up a schematic representation of the ownership structure of a legal entity (samples)

The state registrar must be provided with such a document as the ownership structure. Thus, the state wants to know the ultimate beneficial owners of legal entities.

The regulation on the form and content of the ownership structure, previously approved by order of the Ministry of Finance dated March 19, 2021, No. 163, has passed the state registration procedure with the Ministry of Justice and will enter into force one month after its official publication.

The normative legal act was developed in pursuance of the requirements of the Law “On Prevention and Counteraction to Legalization (Laundering) of Criminally Obtained Incomes, Financing of Terrorism and Financing the Proliferation of Weapons of Mass Destruction”.

The ownership structure can be prepared in any form. It is a schematic representation of all persons who directly or indirectly own an enterprise, independently or jointly with others.

When drawing up the document, it is necessary to indicate the amount of participation of each of the owners, as well as indicate persons who, regardless of formal ownership, have the possibility of significant influence on management or activities. In addition, it is necessary to indicate the description of the implementation and the nature of the decisive influence of the ultimate beneficial owner.

In the event that information about the latter is not clearly tracked according to the data of the Unified State Register of Legal Entities, Individuals - Entrepreneurs and Public Organizations, documents confirming the ability to exercise such decisive influence will have to be attached to the schematic image.

Samples of schematic representation of the ownership structure can be downloaded here.