You may remember that back in November 2022, the European Court of Justice rendered a judgment partially invalidating the most recent anti-money laundering directive. More particularly, it judged that the access to the register of beneficial owner put in place by such directive was too large and potentially conflicted with the right to one’s own personal data.
As a consequence, the access to the Luxembourg register of beneficial owners (“RBE”) was suspended, and only filings of data were possible but no consultation of the register. That changed in mid-December 2022, when access to the RBE was granted in favour of certain categories of professionals (such as law firms).
Now, in a further evolution, since yesterday the access to the RBE was granted to the persons or entities in the RBE in order to allow them to access their own data. The procedure to follow for the relevant entities is somewhat cumbersome and involves receiving a letter sent by the RBE by mail, accessing the RBE website with a LuxTrust or eIDAS certificate and the entering of a PIN code indicated in the letter. Some more details on this procedure can be found under the following link.
Our teams at Bonn & Schmitt would be pleased to assist you with any query in relation to this issue.