New Legal Framework on Beneficial Owner

Law No. 7/26 of 19 August has been enacted, approving the Legal Framework for the Identification, Registration, Record-Keeping, Updating and Disclosure of Information on Beneficial Owners of Legal Persons and Other Entities without Legal Personality ("RJBE"). The law entered into force on the date of its publication, namely 19 August 2026.
 

Scope of Application

The RJBE applies to all private entities, whether domestic or foreign, including both legal persons and entities without legal personality. These comprise, among others, civil and commercial companies, law firms, branches, associations, non-governmental organisations (NGOs), foundations, religious organisations, trade unions, Chambers of Commerce and Industry, funds and autonomous estates, trusts operating in Angola, state-owned investment companies and political parties.

Public entities, public-sector enterprises, diplomatic missions, international public organisations, independent administrative authorities and professional bodies are excluded from the scope of the RJBE.
 

Definition of Beneficial Owner

A beneficial owner is any natural person who ultimately owns or effectively controls, whether directly or indirectly, a legal person or an entity without legal personality, and/or any natural person on whose behalf an act, transaction, business arrangement or economic operation is carried out, or to whom the funds arising therefrom are transferred, directly or indirectly.

In the case of commercial companies, beneficial owners are the natural persons who exercise effective control, including through:

• direct or indirect ownership of an interest representing 25% or more of the share capital or voting rights;
• ownership of a qualifying holding, in case of financial institutions;
• holding senior management functions or exercising effective authority over management, administration or equivalent powers, where a beneficial owner cannot be identified through other means;
• being the person ultimately entitled to the profits generated by the business activity; or
• exercising control or influence by other means, irrespective of the percentage of ownership interest (e.g. powers of attorney, shareholders' agreements, veto rights, special voting rights, or rights enabling influence over senior management or corporate bodies).
   

Central Beneficial Ownership Registry (CRBE)

The RJBE incorporates the CRBE as an autonomous public body responsible for receiving, centralising, registering, updating and disseminating beneficial ownership information. Information will be made available through an electronic platform and will be publicly accessible, subject to applicable legal limitations.

The publicly available information will include, in relation to the beneficial owner: name; marital status; date of birth; place of birth; nationality; country of residence; identification document details; taxpayer number; and the basis upon which beneficial ownership status is established; and in relation to the entity: corporate name; legal form; registered office; taxpayer number; corporate purpose or business activity classification (CAE); and contact details.

The conditions and requirements governing access to, and disclosure of, information held by the CRBE will be established by regulations. Access may, in certain circumstances, be restricted where disclosure could expose an individual to the risk of criminal offences or where the beneficial owner is a minor or lacks legal capacity.
 

Obligations to Maintain and Register Beneficial Ownership Information

Entities subject to the RJBE are required to:

• maintain proper, accurate and up-to-date information regarding their beneficial owners;
• ensure registration with the CRBE upon incorporation or initial registration;
• submit an annual confirmation statement by 31 March of each year; and
• notify any changes within 15 days from the date on which the relevant event occurs.
   

Identification and Due Diligence Obligations of Obliged Entities under Anti-Money Laundering Legislation

Financial institutions and certain non-financial entities, including lawyers, accountants, auditors and real estate agents, are required under the Anti-Money Laundering Law to identify the beneficial owner prior to or upon entering into a business relationship, or when carrying out occasional transactions on behalf of, for the account of, or for the benefit of a client.

Prior identification is mandatory, in particular, in the following circumstances:

• transactions or operations with a value equal to or exceeding USD 15,000;
• electronic transfers with a value equal to or exceeding USD 1,000, including transactions that appear to be linked;
• where there are reasonable grounds to suspect money laundering, terrorist financing or the proliferation of weapons of mass destruction;
• where doubts arise regarding the authenticity, accuracy or adequacy of previously obtained identification information; or
• where justified by the client's risk profile or the characteristics of the transaction.

In addition, such entities must verify client information through the CRBE, confirm compliance with registration obligations and report any discrepancies identified.
 

Transitional Period

Entities already incorporated or operating on the date the RJBE entered into force have a maximum period of 180 days (i.e. until 15 February 2027) to identify and register their respective beneficial owners with the CRBE. However, the operation and implementation of the CRBE remain subject to implementing regulations that are yet to be enacted.
 

Penalties

Failure to comply with the RJBE constitutes an administrative offence punishable by fines which, in the case of legal entities, range from AOA 250,000 to AOA 50,000,000. Additional sanctions may also be imposed, including the temporary restriction from holding corporate office and prohibitions on engaging in certain activities or professions.

The RJBE further establishes criminal liability for the submission of false statements and for the unlawful manipulation of information recorded in the registry.