The full implementation of the REBECO Act, the law that sets up Luxembourg's register of beneficial owners, transposing Article 30 of the European Union's 4th AML Directive, has been delayed yet again. The Act came into force on 1 March and gave companies until 31 August to send the Governemnt their details. Now the deadline has been moved to 30 November.

The reason for the delay appears to be the fact that only three-fifths of companies have sent their details in so far. Beneficial ownership information consists of:

• first and last name(s);
• nationality(ies);
• date and place of birth;
• country of residence;
• address;
• identifying numbers; and
• the nature of the beneficial ownership.

Luxembourg is one of those EU jurisdictions that is far behind the original deadline for compliance set out by article 30 of MLD4, namely June 2017.

Article 15 REBECO Act gives ultimate beneficial owners the right to ask the Government to limit the availability of their information. Only the very vulnerable need apply.