Amendments to the Regime of Identification and Communication of Beneficiaries Owners provided by Act N° 19,484

As we have previously informed, Act N° 19,484, which was regulated by Decree No. 166/017, set forth the obligation of resident entities (and in certain cases also of non-resident entities) to identify and communicate their beneficiaries owners to the Central Bank of Uruguay (BCU). For this purposes, it is considered as entity a legal entity (among others commercial companies), trusts, investment funds or any legal structure (Section22). Likewise, the Act set forth that certain entities are exempt from complying with the aforementioned obligations.


The deadline originally envisaged for the communication of final beneficiaries - and the chain of ownership - to the BCU was as follows:

  • entities obliged to inform by Act N° 18,930, of July17, 2012 (mainly bearer share companies): September 30, 2017;
  • issuers of registered shares, personal companies and other entities: June 30, 2018.

However, Act N° 19,631, recently approved, provided an amendment to the general regime of terms. The referred Act, foresees in his section 7 the adjustment of the terms provided by Act 19,484 inits section 42 for the issuing entities of registered shares, personal companies and other entities according to the following detail:

  1. Companies with registered shares: the deadline for submitting the communication remains unchanged, i.e. June 30, 2018;
  2. Limited liability companies (LLCs) and trusts not obliged to inform by Act 18,930 (these are those trusts abroad whose trustee or administrator resident in the national territory): September 30, 2018.
  3. Other entities bound by the Act: November 30, 2018.


It should be noted that the new regulations only adjust the terms provided by Act 19,484, not setting out other changes than those detailed in the preceding paragraphs. As a result, both, the provisions regarding the penalties for not communicating on time and those related to the entities that are excluded, remain unchanged.

Should you have any comments or questionsplease let us know. 

Héctor Ferreira - hferreira@hughes.com.uy

Lucien Dzimalkowski -  ldzimalkowski@hughes.com.uy