Organizations were required to register their UBOs in the UBO register no later than 27 March 2022. The Economic Enforcement Office (the “EEO”) announced what to expect.
In case the Dutch Chamber of Commerce (the “CoC”) determines that an organization did not register their UBO, they will inform the EEO. The CoC can also receive a message from other authorities, such as bank and Tax Authority regarding an incorrect registration and subsequently inform the EEO.
The EEO will contact the organization by letter or a phone call regarding the UBO registration and remind the organization regarding the obligation. In case the organization received such letter, they will have two weeks as from the date of the letter to complete the registration.
The organization will be in violation in case the registration has not been completed within two weeks after the receival of the letter. The EEO can impose a fine or a penalty. The fine can amount to a maximum of EUR 22,500 and the penalty does not have a maximum amount. If you are not able to pay this fine at once, then you can request for a payment arrangement. There is the possibility to object against the fine and if this objection is rejected, there is the possibility to appeal against this.
The organization is able to contact the Team UBO in case the organization is not able to complete the UBO registration within the two weeks after the receival of the letter or if the organization wants to check whether the EEO has really contacted them by letter or phone.