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Keane Vgenopoulou & Associates LLC has acted as Cyprus counsel to the Dealers, together with Allen & Overy LLP (as to English law), in connection with the establishment by Hellenic Bank Public Company Limited (the “Bank”) of its €1.500.000.000 Euro Medium-Term Note Programme (the “EMTN Programme”).
Public access to the Ultimate Beneficial Ownership (“UBO”) register is held invalid
The UBO Register is a product of the fourth anti-money laundering Directive (MLD 4)1 and the fifth anti-money laundering Directive (MLD 5)2 as part of the EU’s legislative programme for combating money laundering and terrorist financing, through the introduction of transparency in the ownership of companies. In addition to the register of UBOs kept by companies themselves, a Central Register was created. Under MLD4 access was granted only to public authorities and those who could demonstrate a “legitimate interest” in combatting money laundering and terrorist financing. Following the adoption of MLD5, access to the UBO Register was unrestricted and public access was granted.