Transparency of Beneficial Ownership Clashes With U.K. Privacy Laws

The Register of Overseas Entities (ROE) that came into force in the U.K. on August 1, 2022, via the Economic Crime (Transparency and Enforcement) Act 2022 aims to help crack down on foreign criminals using U.K. property to launder money by requiring registration with the U.K. Companies House. However, on November 22, 2022, the Court of Justice of the European Union issued a ruling that prioritizes privacy over transparency and could eventually lead to changes in the approach to registries across Europe. The Cybersecurity Law Report spoke with Crispin Rapinet and Khushaal Ved, attorneys at Hogan Lovells, about the new requirements, the somewhat conflicting CJEU ruling, and what they mean for multinational corporations. See our two-part series on lessons from the WhatsApp decision on GDPR transparency requirements: Enforcement Takeaways (Oct. 20, 2021); and Compliance Foundations (Oct. 27, 2021).

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