Commencement date for Register of Overseas Entities (ROE) changes

A key regulation bringing into force some important changes to the ROE legislation has just been passed.

The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 2 and Transitional Provision) Regulations 2024 was made on 29th February and brings into force a raft of changes made under the Economic Crime and Corporate Transparency Act 2023.  The regulations confirm that the vast majority of these changes come into force with effect from 4th March 2024 (i.e. yesterday).

In relation to the Register of Overseas Entities, the most important changes that are in force from 4th March impact:

1. Overseas entities who hold property as nominee.  These changes are explored in detail in the following article, and in particular paragraphs 3 & 4: The Register of Overseas Entities (ROE) and Nominees (burges-salmon.com); and
2. Trusts that are in the ownership chain of the overseas entity.  These changes are explored in paragraph 6.2 of the following article: The Register of Overseas Entities (ROE) and Trusts (burges-salmon.com)

Helpfully, the regulations include an important transitional provision for Overseas Entities that have already completed their first reporting (and received an OE ID number), but had not completed their update reporting by 4th March 2024.  For these entities the nominee and trust amendments apply to any update statement delivered after 4th June 2024.

As a result, any Overseas Entities that are impacted by these changes and are yet to complete their update statement have an additional incentive to complete this before 4th June 2024.

If you or your client would like further guidance on the impact of the ROE or these changes then please contact Ronnie Myers or your usual contact at Burges Salmon.

The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 2 and Transitional Provision) Regulations 2024

https://www.legislation.gov.uk/uksi/2024/269/made