It’s quite shocking. The General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act was promulgated in December 2022.

It required that all companies submit a Beneficial Ownership Return to CIPC.

We have over 100 shelf companies and, like a good Boy Scout, I personally submitted the returns for all of them. In each case I received an email from CIPC confirming the submission.

On July 1 2024, they introduced a mechanism that stops you submitting your Annual CIPC Return unless you’ve submitted your Beneficial Ownership Return and guess what? Every one of our shelf companies is being blocked, because they can’t see into their own database!

I suspect that this will happen every year despite the fact that the BO return is a once-only unless there’s a change of shareholders.

And then. Who are the beneficial owners of a Non Profit Company? The Act says the shareholders of companies. But an NPC cannot declare dividends, so its shareholders cannot benefit. Therefore they cannot be beneficial owners. Oh well, we’ll enter the shareholders just to be able to submit the Annual CIPC return.