Luxembourg RBE: Compliance failure might soon be prosecuted


Luxembourg RBE: Compliance failure may soon be prosecuted

19 December 2019

Regulatory News Alert

Context and objectives

The Law of 13 January 2019 on Register of Beneficial Owners (the Law), establishing an electronic central register of beneficial owners (RBE) for the legal entities registered on the Luxembourg Trade and Companies Register, entered into force in March 2019. It requires the entities within its scope to register with the RBE (see our previous news alert for further details).

The deadline for registration with the RBE was first set as 31 August 2019, but subsequently extended by the Luxembourg Business Registers (LBR) to 30 November 2019 due to administrative difficulties faced by both the LBR and the entities affected by the Law.

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Legal consequences of non-compliance

In December, the Ministry of Justice reported that—as of December 2019—approximately 87 percent of all concerned entities have registered with the RBE, and are thus compliant with the due date for reporting.

Furthermore, the Ministry of Justice announced that the remaining, non-compliant entities would soon be reported to the public prosecutor who may then press charges against them. Thus, non-compliant entities are highly recommended to take remedial action and register with the RBE as soon as possible.

How can Deloitte help?

To ensure your compliance with the beneficial ownership transparency requirements, Deloitte has developed a dedicated filing solution and can help you with your RBE registration obligations.

Deloitte’s AML/CTF advisory specialists and dedicated services will also help you design and implement your renewed business strategy in light of the future evolution of the AML/CFT framework.

Key Deloitte AML services are:

  • AML/KYC remediation plan
  • AML/CTF training
  • AML/CTF policy, procedure, and process design or review
  • DKYC: externalising KYC processes
  • Qualification and set up of Responsable du respect des obligations and Responsable du contrôle du respect des obligations (as required by the Law of 12 November 2004—we reported

With our Regulatory Watch Kaleidoscope service, Deloitte can also help you stay ahead of the regulatory curve to better manage and plan upcoming regulations.


Subject matter specialists

Pascal Eber
Partner – Operations Excellence &
Human Capital
Tel : +352 45145 2649

Eric Collard
Partner – Forensic & AML, Restructuring
Tel : +352 45145 4985

Bastien Collette
Director – Advisory & Consulting (AML/CTF)
Tel : +352 45145 3372

Alice Lehnert
Director – Advisory & Consulting
Tel : +352 45145 2605

Regulatory Watch Kaleidoscope service

Simon Ramos
Partner – IM Advisory & Consulting
Leader and Regulatory Watch Co-Leader
Tel : +352 45145 2702

Jean-Philippe Peters
Partner – Risk Advisory and Regulatory Watch Co-Leader
Tel : +352 45145 2276

Benoit Sauvage
Director – Regulatory Watch Coordinator
Tel : +352 45145 4220

Marijana Vuksic
Manager – Strategy, Regulatory & Corporate Finance
Tel : +352 45145 2311

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