LBR Circular 26/01: Luxembourg Business Registers (LBR) has clarified the beneficial ownership reporting requirements applicable to companies held by a trust or foundation and subject to the Beneficial Owners Register (Registre des bénéficiaires effectifs, or RBE).
Under Circular LBR 26/01, dated 19 August 2026, the company must register the beneficial owners of the underlying trust or foundation, namely:
– the settlor(s);
– the trustee(s);
– the protector(s), if any;
– the beneficiaries – or, where they have not yet been determined, the relevant category of beneficiaries; and
– any other natural person exercising ultimate control.
This clarification means that RBE reporting must cover the relevant parties to the trust or foundation, rather than being limited to the persons directly holding or controlling the Luxembourg company.
The registered information includes each beneficial owner’s identification details, as well as the nature and extent of their beneficial interests. LBR’s position is consistent with Article 55 of Regulation (EU) 2024/1624, although the Regulation is not yet mandatory.
Access the full text of Circular LBR 26/01 here: https://lnkd.in/ebAqE7T6
For any questions or further information, please reach out to Xavier Hamori, Authorised Director, VPsf, or Gaelle Kwiatkowski, Head of AML/KYC.
LBR Circular 26/01: Luxembourg Business Registers (LBR) has clarified the beneficial ownership reporting requirements applicable to companies held by a trust or foundation and subject to the Beneficial Owners Register (Registre des bénéficiaires effectifs, or RBE).
Under Circular LBR 26/01, dated 19 August 2026, the company must register the beneficial owners of the underlying trust or foundation, namely:
– the settlor(s);
– the trustee(s);
– the protector(s), if any;
– the beneficiaries – or, where they have not yet been determined, the relevant category of beneficiaries; and
– any other natural person exercising ultimate control.
This clarification means that RBE reporting must cover the relevant parties to the trust or foundation, rather than being limited to the persons directly holding or controlling the Luxembourg company.
The registered information includes each beneficial owner’s identification details, as well as the nature and extent of their beneficial interests. LBR’s position is consistent with Article 55 of Regulation (EU) 2024/1624, although the Regulation is not yet mandatory.
Access the full text of Circular LBR 26/01 here: https://lnkd.in/ebAqE7T6
For any questions or further information, please reach out to Xavier Hamori, Authorised Director, VPsf, or Gaelle Kwiatkowski, Head of AML/KYC.
