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According to the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act 2022, the Directors of every company are required to submit a return of the Beneficial Owners (usually the shareholders) of their company to CIPC. Then they only have to submit another if, and when, the beneficial ownership changes.

At this stage, I am not convinced that CIPC will only impose this obligation once or will require a new Beneficial Ownership along with the submission of every annual return.

We’ll have to wait and see whether or not they get it right.

In the meantime, however, they have issued Notice 39 of 2024 to the effect that from 1 July, it will not be possible to submit an Annual CIPC return unless the Beneficial Ownership return has been submitted.


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