Seychelles Annual Review of Beneficial Ownership Information

– Regulation 13, Beneficial Ownership (Amendment) Regulations 2023

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Further to the regulatory changes implemented through the Beneficial Ownership (Amendment) Regulations 2023 (the BO Regulations) as detailed in our previous update(s), from 1 January 2025 onwards Regulation 13 requires Seychelles entities to verify their Beneficial Ownership (BO) information at least once per calendar year to ensure filed records are accurate.

Timing

The required annual review must commence within three months of the Company’s anniversary date, and the information (below) will be supplied to the Company’s Registered Agent within one month after the Company’s anniversary date.

We, at Marbury, will reach out to you ahead of your Company’s deadline.

BO information 

The information required from the Company is as follows:

• compliance request for updated KYC in relation to the Company and submission of the same to the Registered Agent
• completion and filing of the Declaration of Compliance, which includes confirmation of the following therein:
  • that all BO information is up to date (or if there are changes to note)
  • that the current BO information has been received and confirmed by the BOs
  • supporting documents have been provided and verified, including Tax Identification Numbers (TIN) or National Identification Numbers (NIN)

How does this affect me?

All Seychelles Companies will be required to undertake yearly BO confirmations, and Registered Agents must ensure that accurate and up-to-date records are kept and filed.

As the BO Regulations presently stand, BO information will not be publicly available. Access is limited to the Registered Agent, the Seychelles Registry, and approved regulatory bodies.

Penalties for non-compliance

Companies which fail to comply and submit their annual Declaration of Compliance shall be liable to a penalty not exceeding SCR20,000.

What are the steps for a Seychelles Company to remain compliant?

All changes in the beneficial ownership of the Company must be notified to your company secretary to ensure that updated records are kept and filed with the Registered Agent. When BO changes occur, please reach out to us at Marbury as soon as possible for us to ensure compliance. Seychelles entities are hereby reminded of the obligation to also inform the Registered Agent of any change of address of directors or members on an ongoing basis. Inaccurate or out-of-date information held on the registers may also incur penalties.

Should you have any queries regarding the BO information review or about the general compliance obligations of your Seychelles company, please contact your usual Marbury relationship manager or alex.sharpe@marburys.com.