Bermuda Beneficial Ownership Regime - Deadline Extension and Clarification to Public Company Exemption

The deadline for obtaining, verifying and filing beneficial ownership information on applicable Bermuda companies, LLCs and partnerships has been extended to 15 December 2018.

This advisory is issued further to our client advisory of 2 July 2018 regarding the implementation of an enhanced beneficial ownership regime in Bermuda. The Minister of Finance has now issued a notice extending the deadline for all Bermuda companies and partnerships (unless exempted) to establish such a beneficial ownership register (if necessary, verify and update the same) and make the necessary filings with the Bermuda Monetary Authority from 24 September 2018 to 15 December 2018.
 
In addition, the Ministry of Finance has clarified that all Bermuda companies which are a "subsidiary" of a company or entity, wherever incorporated, which is listed on an appointed stock exchange or the Bermuda Stock Exchange are exempted from the requirement to prepare and maintain a beneficial ownership register.
 
The Ministry of Finance is expected to issue further guidance in respect of the form of the required beneficial ownership register and procedures for verifying beneficial owners shortly.  We will provide further information in due course.
 
The team at Taylors is here to help.  Taylors has a detailed understanding of the applicable legislation, and is providing assistance to clients on all aspects of the new beneficial ownership regime.