Ultimate Beneficial Owner

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The Ultimate Beneficial Owner (UBO) is a new EU law that came into existence on 31 October 2018. Enterprises and organisations are obliged to declare relationships with other entities or natural persons (e.g. Board members). The goal is to detect, investigate, and prevent money laundering.

Note: since 1 januari 2019 the VZW wetgeving has also changed: according to the Belgian law a non-profit organisation is considered an enterprise (simplication/unification of laws because of UBO).


Prevent (international) financial abuse (fraud, terrorism).


The Ministry of Finance of Belgium keeps the UBO register.

Declaration of the natural persons that are responsible for the Non-profit organisation: the Board.

It is sufficient to complete and maintain the register at the MinFin web site before 31 March 2019 30 september 2019, and amend or approve yearly.

Question: Why isn't this (automatically) linked or included in the statutory publication or the KBO? Why is a third register necessary?


Non-compliance can cause huge penalties.


As a legal European obligation that is due 31 March 2019 30 september 2019, the board has been registered (by the Chairman of Wikimedia Belgium) as UBO because they are Board member of an VZW/ASBL.

See https://eservices.minfin.fgov.be/ubo

Each individual registered Belgian board member can verify (or even change) the registration by logging in with their e-ID.

  • To see/change the personal registration, connect as a person
  • To see/change the Wikimedia Belgium registration, connect as an enterprise

The board members were informed about this registry by the Chairman of WMBE, as part of the GDPR, and by the administration of the Ministry of Finance.

The register needs to be amended at every change in Board membership, after registration at KBO and the Staatsblad, via the e-ID of one of the registered board members, and re-approved yearly even if there were no changes.

This implies that board member changes needs to be registered 3 times.

Because of the UBO and the KBO registration the WMBE GDPR privacy declaration has also been amended (national number for board members).

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