How is information on the beneficial owner provided if one of the shareholders who meets the criteria for identification as a beneficial owner has died and the succession procedure has not been completed?

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If the beneficial owner has died and the certificate of inheritance has not been issued due to procedural circumstances arising in the course of the succession proceedings, the Declaration on the BO shall indicate:

  • the natural person holding the position of administrator of the legal entity, if the shareholder identified by the administrator was the only person who, prior to the death, had the status of beneficial owner, in accordance with the provisions of Article 52 para. (2) point 1) letter a) of Law No. 308/2017;

  • the natural person/natural persons who meet the criteria defined by Article 52 para. (2) point 1) letter a) of Law No. 308/2017, other than the deceased person, if the deceased shareholder was not the only person identified by the administrator as the beneficial owner prior to their death.