Law no. 315/2021, published in the Official Gazette on Dec. 29.12.21, makes some important changes, simplifying the obligation to file the actual beneficiary declaration , to Law No. 129/2019 on anti-money laundering. We will summarize in this newsletter the most important points of the repeal of the (partial) beneficial owner declaration.
The obligation to submit the annual declaration of beneficial owners is repealed for those companies in which individuals residing in Romania, the European Union or third party states considered by the competent authorities to be fiscally cooperative participate.
The obligation to submit the annual declaration with the real beneficiaries is maintained for those companies participated by individuals residing in jurisdictions considered by the Romanian tax authorities to be non-cooperating.

AML authorities will develop a public registry with these non-cooperating tax jurisdictions.
The obligation to submit the declaration of beneficial owners at the time of incorporation of the company, regardless of the organizational form, remains in place.
The obligation to submit the declaration of beneficial owners within 15 days of the change in either the structure of equity participants or identifying elements is maintained.
If a company has already filed a declaration with real beneficiaries and no changes have occurred, the company is exempt from filing the declaration.
If a company has not filed the declaration of actual beneficiaries, the deadline for filing the declaration is 90 days after the end of the state of emergency (due to Covid)

The regulatory change will be implemented during 2022, and accordingly more details will be provided in this context.