The deadline determined by the Brazilian Federal Revenue, in Normative Instruction No. 1,863/2018, so that national or foreign entities registered before the CNPJ (National Registry of Legal Entities) must update its their corporate structure until identify the existence or non-existence of a natural person, considered/classified as final beneficiary, regardless of the levels of the structure and origin of the Brazilian or foreign capital, ends in late June.
The update of this information is mandatory and, depending on the situation, in the absence of this update, the company may have its registration before the CNPJ suspended and even prevented from transacting/using bank accounts, including moving current accounts, making financial investments and obtaining loans. In the case of companies domiciled abroad that are holders of rights on investments in the financial or capital market, the suspension of the CNPJ will be reported to the Brazilian Securities and Exchange Commission (CVM).
Recently, the Law Bill n. 77/19 was presented in the House of Representatives. It aims the synchronization of the collected data between the Brazilian Federal Revenue and Commercial Boards and, in articulation with the Department of Business Registration and Integration, the production of manuals and reference documents.
Our Public and Regulatory, Banking and Financial Law sectors continue to monitor the compliance with this rule and are available to provide any assistance related to the subject.