Beneficial owner – non-compliance of data – implementation of Article 23 of the Law on Central Records of Beneficial Owners

The transitional provisions of Article 23 of the Law on Central Records of Beneficial Owners (RS Official Gazette, No 19/2025 – hereinafter: Law) introduce, until the start of the full application of this Law, a temporary solution responding to the cases of non-compliance of data on beneficial owners[1] of registered entities[2] in the Central Records of Beneficial Owners (hereinafter: Central Records) and data about the beneficial owners of such entities – customers with the obligors[3]. This temporary solution ensures appropriate action of all participants in the system prior to the full application of the Law, from registered entities, through obligors to supervisory and other competent authorities, in order to prevent abuse and ensure maximum transparency and compliance of data about beneficial owners. In addition, this solution ensures that interested parties are timely informed about the established non-compliance of data about the beneficial owner of the registered entity.

The solution requires that the obligor, when determining the beneficial owner of the customer by applying customer due diligence actions and measures prescribed by the law governing the prevention of money laundering and terrorism financing, must obtain the data about the beneficial owner of that customer from the Central Records of Beneficial Owners and compare them with the data obtained through application of the mentioned actions and measures. If the obligor has established that the data about the beneficial owner of the customer obtained from the documents submitted by the customer differ from the data in the Central Records or that such data are not registered in those Records, the obligor shall, without delay, notify the authority tasked with supervising that obligor in accordance with the law governing the prevention of money laundering and terrorism financing. Upon receiving the notification from the obligor, the supervisory authority shall publish on its website the list of registered entities in which the above-described data non-compliance was established.

The National Bank of Serbia, as an authority supervising the implementation of the law governing the prevention of money laundering and terrorism financing in a significant number of financial institutions[4] in the Republic of Serbia, receives notifications about the non-compliance of data on beneficial ownership of clients of the financial institutions that it supervises.   

The list of registered entities regarding which the National Bank of Serbia was notified about the identified non-compliance of data about beneficial owners registered in the Central Records and data on beneficial owners of those entities – customers which the obligor has established, may be accessed via the following link:

Note: The National Bank of Serbia shall not be responsible for the accuracy of published data regarding the non-compliance of data about the beneficial owners of registered entities, given that it does not verify their accuracy based on the credible documents and data, but receives those data and information from the supervised entities under its jurisdiction and updates them accordingly.

[1] Beneficial owner within the meaning of Article 3, paragraph 1, item 7) of the Law on Central Records of Beneficial Owners.
[2] Legal persons and other entities registered in the Republic of Serbia pursuant to the Law.
[3] Оbligors of the implementation of the law governing the prevention of money laundering and terrorist financing.
[4] Banks, voluntary pension fund management companies, financial lessors, insurance undertakings, insurance brokerage undertakings, insurance agency undertakings, electronic money institutions, payment institutions, public postal operator headquartered in the Republic of Serbia, authorised exchange dealers or business entities performing exchange operations based on a separate law governing their activity, digital assets service providers.