As we previously informed on 28 April 2020, most provisions of the Law of Ukraine "On Prevention and Counteraction to Legalization (Laundering) of Proceeds Received through Crime, Terrorism Financing, and Financing of Proliferation of Weapons of Mass Destruction" (the "AML Law") came into force. The AML Law establishes new rules for disclosure of information on ultimate beneficial owner(s) ("UBOs") and introduces changes to the Law of Ukraine "On State Registration of Legal Entities, Individual Entrepreneurs and Public Formations" the "State Registration Law")).

To implement new legislative provisions, duly interpret them and form the practice of their application, the Ministry of Justice of Ukraine (the "Ministry of Justice" or the "Ministry") already issued a number of orders and clarifications, including letter No. 3887/8.4.4/32-20 dated 23 April 2020 (the "Clarification"). Below we outline the key points highlighted in the Clarification.