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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. I have a client who owns 49% of the members’ interest and a Trust which owns 51%. This is a CC. The Trust was formed for BEEE purposes between my client and Serr Synergy.
    What would you charge for a BO Certificate from CIPC – failing which, could you point me to the list of docs required by CIPC for the Trust in this regard?

    1. Hi Chez,
      There are two BO registrations needed. One for the trust itself and another for the CC.
      For the trust our fee is R2 900 for 2 trustees plus R450 for the founder (if not one of the trustees or named beneficiaries) and every additional trustee or named beneficiary (who is not also a Trustee).
      Let me simplify that. If one person acts in more than one capacity, we only charge for that person once. So, add up how many different people comprise the founder, the trustees and the named beneficiaries. Subtract 2 from that total, multiply the result by R450 then add R2 900.
      For the CC, the fee is R2 100 plus the same number above times R450, unless your client is not the founder, a trustee or a beneficiary of the trust in which case add one more R450 on top of the figure you just calculated.
      If you email me the numbers, I will send you a quotation.
      If you think this is complicated, it is nowhere near as complicated as submitting the returns. 🙂

  2. 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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