On 5 January, Carey Olsen provided a briefing on the Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 and associated secondary legislation, which entered into force on 6 January and establishes a new, central register of beneficial owners and significant persons in Jersey. The new law is intended to satisfy FATF Recommendation 24 on beneficial ownership of legal persons, and the types of entities covered are companies, foundations, Incorporated Limited Partnerships (ILP), Separate Limited Partnerships (SLP), Limited Liability Companies (LLC) and Limited Liability Partnerships (LLP). It says that most of the relevant information (and more) is already reported to and centrally held by the Jersey FSC as part of its function as financial services regulator. Information on beneficial owners will not to be made publicly available, and a decision on whether and, if so, when and the extent to which such information may be made public will be deferred until a consensus on approach has been reached in the EU, anticipated to be some time in 2022. Information on significant persons will be made publicly available on the FSC’ website, subject to exceptions, from mid-2021. The information to be made public will relate to current significant persons only. Nominated person information will not be made publicly available, nor will information on who has nominated a “nominated director”.
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