In Pakistan, companies are required to file a UBO return with the Securities and Exchange Commission (SECP) in order to disclose their ultimate beneficial owners (UBOs). The UBO return must be filed by companies upon the request of the SECP and must be updated whenever there are any changes to the company’s ultimate beneficial ownership.
Failure to file the UBO return or to disclose accurate and complete information can result in fines and penalties for the company and its directors. The specific penalties for not filing a UBO return in Pakistan are set out in the Companies Act, 2017 and the relevant regulations.
Under the Companies Act, 2017, the SECP has the power to impose fines on companies and their directors for failure to comply with the requirement to file a UBO return or to disclose accurate and complete information. The amount of the fine may vary depending on the severity of the violation and the circumstances of the case. Usually on first notice, it is Rs 20,000. Failure to do so after first notice, penalty can be extended to 1 Mn for each director and 10 Mn for Company.
It’s worth noting that failure to file a UBO return or to disclose accurate and complete information may also result in reputational damage for the company and may make it more difficult for the company to do business or to raise capital. It is important for companies in Pakistan to comply with the requirement to file a UBO return and to disclose accurate and complete information in order to protect their reputation and to avoid fines and penalties.