Law No. (1) of 2020 regarding the Unified Economic Register (“Unified Register Law”).
The Unified Register Law aims to create a unified economic register at the Ministry of Commerce and Industry that promotes transparency of economic and financial transactions and to gather fundamental information, data and instruments such as commercial registrations, articles of association, documents related to the real (ultimate) beneficiary of the company as well as legal documents of companies, corporations, funds, civil companies (i.e. freelance professions) as well as non-profitable organizations under one legal umbrella that could then be used and shared with the concerned authorities in Qatar such as the judiciary, QFMA and QCB for compliance and investigations purposes.
Each corporation, company and any entity would be given a unified economic number upon its registration for the first time to facilitate the work of the unified register. Such documents will be available to the public.
Confidence and Transparency
The Unified Register Law obliges the concerned authorities to operate the full principles of security, confidence, secrecy and good governance when dealing on any information related to entities that are subject to the Unified Register Law. It is also expected that the Unified Register Law would have a positive impact on tracking and combating money laundry and terrorism crimes through tracking the ultimate beneficiaries of the entities that are subject to the register.
Real (Ultimate) Beneficiaries Disclosures
The Unified Register Law obliges the addressed entities to disclose and report to the Competent Authority (e.g. Ministry of Commerce and Industry) regarding the information related to the ultimate beneficiary of the entity when registering the entity for the first time or upon conducting any amendment to the structure of the said entity. The Unified Register Law obliges the addressed entities to have updated register where all information and data related to ultimate beneficiaries shall be kept. Moreover, regular updates shall be made to the said register by the addressed entities and copy of the register shall be sent to the Competent Authority.
How to obtain information
Article (7) of the Unified Register Law allows an interested person to apply for obtaining information on a specified corporation from the unified register. The Competent Authority should review the application and make sure of satisfying the interest criterion and then should release the required information based on its discretion.
Moreover, and as mentioned above, investigations, supervisory, judiciary and compliance authorities in the state may request information from the register for the purposes of their work.
Articles (11) and (12) of the Unified Register Law impose the following punishments in case of non-compliance where the Competent Authority (defined as: each authority that handles the licensing or registration of an economic entity, or legal arrangements, or non-for-profit institution or professional occupations) may impose any of all of the following actions in case of non- compliance by the addressed entity:
- (i) Order the entity to submit regular report on the rectifying measures it took to comply with the Unified Register Law.
- (ii) Order the entity to comply with certain instructions.
- (iii) Sending a written notice.
- (iv) Suspension of managers and/ or board member(s) of the companies, as well as legal counsels or executive officers of non-for-profit organizations.
- (v) Suspension of license for a period not exceeding one year.
- (vi) Cancelling the license or striking off the commercial name, as the case may be.
- In addition, the Unified Register Law also impose the punishment of a maximum of two years and a fine of maximum 500,000 QAR in case the addressed entity did not have the register that specifies information on ultimate beneficiaries and/or did not submit a copy of that register to the Competent Authority.
If the Competent Authority is subject to a special law their obligation to comply with the Unified Register Law will be limited to their obligation to provide basic information in relation to real (ultimate) beneficiaries. The Executive Regulations will organize the implementation of this exception.
It is expected that a new executive regulation will be enacted to list and explain the procedures to be followed with respect to the Unified Register Law.
Rectification Grace Period
Article (14) of the Unified Register Law gives all concerned entities that are addressed by this law to rectify their legal requirements within 6 months. The Unified Register Law also gives the Cabinet of Ministers the right to extend the said period for same term or terms, as the case may be.
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