The training session held on 24 February and aimed at developing skills for the proper identification of the ultimate beneficial owner marked the completion of one of the stages of the UCIF project
The training session held on 24 February and aimed at developing skills for the proper identification of the ultimate beneficial owner marked the completion of one of the stages of the UCIF project
The Strengthening Ukraine’s Capacity to Counter Illicit Finance (UCIF) aims to lay the foundations for a long-term, systemic reform of Ukraine’s financial ecosystem. The project brings together government institutions, regulators, law enforcement agencies, financial institutions, and international partners to reduce the scale of the shadow economy, increase transparency in the financial sector, and combat money laundering. It is implemented by DAI Global with the support of the UK Foreign, Commonwealth & Development Office (FCDO).
This training was organised by the Center for Financial Integrity in partnership with the Centre for Finance and Security (CFS) at RUSI and the Academy of Financial Monitoring.
Since September 2024, obliged entities conducting primary financial monitoring have submitted more than 16,000 notifications regarding identified discrepancies related to ultimate beneficial owners (UBOs) or the ownership structure of legal entities. Approximately 90% of notifications are submitted by banks; however, information is also provided by public authorities, law enforcement bodies and other obliged entities.
In June 2025, amendments were introduced to the relevant regulatory acts, including the approval of a new Notification of Discrepancy form, a template request from the state registrar for the provision of explanations, and a template notification letter from the state registrar regarding the results of the review.
Cases that are not classified as discrepancies and do not require a Notification:
Absence in the Unified State Register (USR) of information on a UBO or ownership structure;
A discrepancy in the UBO’s address within Ukraine;
Rounding of the percentage of beneficial ownership;
A grammatical error in the full name which does not prevent identification, provided other data match;
A discrepancy arising from Ukrainian transliteration, provided that the English spelling fully corresponds.
Legal entities are subject to liability for breaches of legislative requirements concerning the disclosure of information about ultimate beneficial owners (UBOs).
At present, liability is established, in particular, for:
Knowingly submitting false information regarding a legal entity’s UBO;
Failure to submit or late submission of information on a UBO or on the absence thereof;
Failure to provide, upon request of a legal entity, information necessary for that legal entity to submit or update UBO and ownership structure data in the Unified State Register.
Until the end of martial law, the application of liability for failure to submit or late submission of information, as well as for failure to provide information upon request, has been suspended. Following the termination or cancellation of martial law, legal entities will be granted 90 days to update their information.
Liability is enforced by the Ministry of Justice of Ukraine. This includes the imposition of a fine ranging from 1,000 to 20,000 non-taxable minimum incomes of citizens. The regulator informs obliged entities and the relevant legal entity in advance about identified discrepancies, their number and the results of their consideration.
Under the updated methodology, civil society organisations may not have a UBO. However, in order to substantiate the absence of a UBO, a thorough analysis of the organisation’s constitutional documents is required.
Among the main reasons for incorrect identification of UBOs:
Insufficient understanding of legislative specifics by financial monitoring entities;
Automatic recognition of founders of public associations as beneficiaries;
Lack of a risk-based approach among national stakeholders.
Such errors may result in the blocking of organisational accounts and the imposition of financial penalties.
YouControl, a Ukrainian IT company specialising in open-data-based technologies, offers a range of tools for analysing links between enterprises, organisations and related persons:
International approaches to defining and disclosing information on ultimate beneficial owners are shaped in accordance with the standards of the Financial Action Task Force (FATF), which sets global rules on combating money laundering and terrorist financing.
FATF Recommendations 24 and 25 establish key principles for working with UBO information, namely:
Ensuring the accuracy and up-to-date nature of beneficial ownership data relating to legal persons;
Preventing the misuse of corporate structures for money laundering or terrorist financing;
Ensuring effective access by competent authorities to information on control and ownership;
Promoting transparency of legal arrangements, including trusts and similar structures.
The application of these principles enhances transparency of ownership and control of legal entities, complicates the misuse of corporate structures for illicit operations, and strengthens the effectiveness of anti-money laundering and counter-terrorist financing measures. This provides a robust instrument for public authorities and financial institutions in combating economic crime.
12 February 2026
