By means of Law 2155 of 2021 and Resolution No. 164 of 2021, the Ultimate Beneficial Owner Registry (“RUB”) and Unincorporated Structures Registry (SIESPJ), which are administered by the Colombian Tax Authority (“DIAN”).

Prior to providing information, legal entities, unincorporated entities and similar must register and update their Colombian Registry (“RUT”) including the responsibility “Informant of Final Beneficiaries”.

The DIAN further issued Resolution No, 1240 of September 28^th, 2022, extending the deadline to report beneficial owners in the RUB and SIESPJ, with the following timeframe:

Initial Registry

• Legal entities, unincorporated or similar structures incorporated or created before May 31, 2023, must make the initial provision of information in the RUB no later than July 31, 2023.
• Legal entities, unincorporated or similar structures incorporated or created on or after June 1, 2023, must make the initial provision of information in the RUB no later than 2 months after registration in the Single Tax Registry (RUT) or registration in the Unincorporated Legal Entity Registry. (If applicable).

Updates

• The updating of the information reported in the RUB must be done by determining whether on the first day of the months of January, April, July and October of each year if any conditions of the UBO/s of the company change. In case of modifications, the information shall be updated within the following month, counted as of the first day of the months of January, April, July and October, as applicable.
• The updating of the information reported in the SIESPJ must be updated within one (1) month from the event that requires the updated information.