Supervision of beneficial owner details

These instructions apply to parties subject to the reporting obligation (e.g. banks, auditors and law firms), supervisory authorities, and the Finnish Bar Association as referred to in the Finnish Act on Money Laundering. They must act as follows:

  1. Parties subject to the reporting obligation must identify the actual beneficial owners of their customers. Read more about actual beneficial owners.
  2. Parties subject to the reporting obligation, supervisory authorities, and the Finnish Bar Association must report to the PRH if they discover deficiencies or inconsistencies in the beneficial owner details entered in the Finnish Trade Register.

The obligations are based on the Act on Money Laundering.

Compare your details with the details in the Trade Register

A submitted notification of beneficial owners is indicated on the company’s Trade Register extract and in the Virre Information Service. Read more about information services and details on beneficial owners.

Compare your details on the customer's beneficial owners with the details in the Trade Register.

You do not have to report to the PRH if the customer’s beneficial owner details have not been entered in the Trade Register. However, we recommend that you advise your customer to file the notification of beneficial owners without delay.

What to do if you discover deficiencies and inconsistencies in the beneficial owner details?

If the beneficial owner details entered in the Trade Register differ from the details in your possession, act as follows:

  1. Make sure that the details in your possession are correct.
  2. If you still consider the details in the Trade Register to be incorrect or deficient after checking them, ask your customer to update the beneficial owner details in the Trade Register.
  3. If the customer has not submitted the notification of beneficial owners within one week, file a supervisory notification with the PRH. Monitor the customer’s details during this time. You can also immediately notify the PRH of the deficiencies or inconsistencies you have discovered. Go to our instructions: How to file a supervisory notification.

Please note that filing a supervisory notification with the PRH does not eliminate or lessen your obligation to identify the customer’s actual beneficial owners.

What will the PRH do after receiving the supervisory notification?

We send a letter to the company or organisation concerned in the supervisory notification, asking the company or organisation to remedy the reported deficiencies in its beneficial owner details within a given time, i.e. within approximately three weeks.

If the company or organisation does not update its beneficial owner details within the given time, we will consider possible further actions case by case. We may decide to remove the beneficial owner details from the company’s or organisation’s Trade Register details.

As of 2021, it will be possible for us to record in the Trade Register details an entry about the deficiencies or inconsistencies discovered in the beneficial owner details.

See the legislation for more information

Provisions on the identification of the customer’s actual beneficial owners are laid down in chapter 3, section 6, subsection 1 of the Act on Money Laundering.

Provisions on the obligation to report any deficient and inconsistent beneficial owner details are laid down in chapter 6, section 5 of the Act on Money Laundering.

Provisions on parties subject to the reporting obligation are laid down in chapter 1, section 2, subsection 1 of the Act on Money Laundering.

Provisions on the supervisory authorities and the Finnish Bar Association are laid down in chapter 7, section 1, subsections 1 and 2 of the Act on Money Laundering.

Read more about the Act on Money Laundering in the reference database of Finnish legislation Finlex:

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Latest update 15.09.2020