The NBS Head Office Building was built from 1888 – 1890, on the basis of blueprints designed by Konstantin Jovanovic (Vienna 1849 – Zurich 1923), son to distinguished artist Anastas Jovanovic...
As of the start of application of the Law on Central Records of Beneficial Owners (RS Official Gazette, Nos 19/2025, 51/2025 and 60/2025 – correction, hereinafter: Law), i.e. 1 October 2025, when determining the beneficial owner of the customer by applying customer due diligence (CDD) actions and measures prescribed by the law governing the prevention of money laundering and terrorism financing, the obligor is required to obtain the data about the beneficial owner of that customer from the Central Records of Beneficial Owners and compare them with the data obtained through application of the mentioned CDD actions and measures. If the obligor establishes that the data about the beneficial owner of the customer obtained from the documents submitted by the customer differ from the data in the Central Records or that such data are not registered in those Records, the obligor shall, without delay, notify the customer and make a NOTE on non-compliance of data through the Portal accessed via the Business Registers Agency’s website and upload the supporting documents.
The submission of the note and documents, including personal data, shall be made without the consent of the customer and the person to whom those documents and note relate.
The registered entity, trust, or a legal arrangement similar to a trust for which there is an obligation to register beneficial owners in accordance with the Law, shall check within 30 days of entering the note in the Central Records of Beneficial Owners whether the recorded data on the beneficial owner are accurate and up-to-date and whether any change should be made to those data and the documents.
If, upon the expiry of the 30-day period, the recorded data and documents on the beneficial owner are not harmonised with the data and documents held by the obligor, the obligor shall notify of the identified non-compliance the authority competent for the supervision of the registered entity. An obligor that has determined that there is a discrepancy in the data on the beneficial owner of a client subject to the NBS’s supervision shall, upon the expiry of the prescribed time period, notify the NBS of the discrepancy in the data on the beneficial owner of that client. The obligor shall notify the NBS of the identified discrepancy in the data for a client that is a: bank, voluntary pension fund management company, financial lessor, insurance undertaking, insurance brokerage undertaking, electronic money institution, payment institution, authorised exchange dealer, or provider of digital asset services.
If the obligor determines a discrepancy in the data on the beneficial owner of a client that is a registered entity outside the competence of the NBS (other companies, citizens’ associations, cooperatives, branches of foreign companies, business and other associations, foundations and endowments, institutions, representative offices of foreign companies, foundations and endowments, trusts and legal arrangements similar to a trust), the obligor shall, upon the expiry of the prescribed period, notify the authority competent for the supervision of that registered entity.
Note: The obligation determined by the transitional provisions of Article 23 of the Law ceases as of the start of application of the Law, i.e. 1 October 2025. Pursuant to those provisions, the obligor was required to notify of the non-compliance of data on beneficial owners in the Central Records and data obtained through CDD to the supervisory authority in change of supervising the obligor in accordance with the law governing the prevention of money laundering and terrorist financing.
