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The General Laws (Anti Money Laundering and Combating Terrorism Financing) Amendment Act was a futile attempt to avoid our being grey listed. It became law in December 2022 and requires that all companies submit their Beneficial Ownership return to CIPC, and to re-submit whenever this information changes.

CIPC have almost got it together and we’ve been able to submit the return for all our (over 100) shelf companies.

That was pretty easy, because I’m the only shareholder, so they were all the same.

Companies owned by shareholders who are natural persons are, actually, relatively easy once you have cracked the system.

We screwed it up a few times before we got the hang of it.

Then it gets fairly tricky when you are doing it for either a company that is a subsidiary of a holding company or a company that is owned by a trust.

In the first case, the Beneficial Owners are the shareholders of the holding company, and in the second case, they are the founder, the trustees and the named beneficiaries of the trust. Try completing that return!


  1. Do you have to be a CIPC customer to verify that your service provider has indeed named you as the UBO?

    1. The Beneficial Ownership data is only available to certain authorities such as law enforcement, SARS etc. It is not available to the general public. Your service provider will have received a confirmation that he/she registered the Beneficial Ownership and should have sent it on to you.

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