Information System of Participants of Legal Entities JADIS/ JANGIS

As part of the practical implementation of the Law of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing, for all legal entities established in the Republic of Lithuania, it is necessary to provide data on their beneficiaries – individuals.

Data on beneficiaries is required by all Lithuanian financial and government institutions to identify their clients and their final beneficiaries. The provision of data on beneficiaries also increases transparency and ensures the effective implementation of measures to prevent money laundering and/or terrorist financing.

The data in JANGIS is only provided in electronic form after connecting to the customer self-service system of the Registration Center, and the lists of beneficiaries formed on the basis of these data are signed with an electronic signature.

Description of JANGIS system

The purpose of the information system of participants of legal entities (hereinafter referred to as the System) is to collect and provide data to individuals and legal entities entitled to receive data on:

• Participants of legal entities (closed joint-stock companies, small partnerships, public institutions, agricultural societies, cooperative societies (cooperatives), real partnerships and faith-based partnerships, charitable and auxiliary foundations that are non-governmental organizations);
• beneficiaries of all organizational and legal forms of legal entities and subjects of collective investment (with the exception of legal entities whose sole participant is the state or municipality.

Data collection on participants of legal entities is carried out in the subsystem of participants of the Information System of legal entities (hereinafter – JADIS), data collection on beneficiaries of legal entities is carried out in the subsystem of beneficiaries of the Information System of Legal Entities (JANGIS).

The main functions of the System are:

1. Systematize, analyse and summarize the data collected by the System;
2. Exchange data with other institutions;
3. Enter data on participants of legal entities, beneficiaries of legal entities and subjects of collective investment and form lists of participants and beneficiaries;
4. Collection, processing and management of data on participants of legal entities, beneficiaries of legal entities and subjects of collective investment;
5. Provide data and documents to individuals and legal entities in accordance with the procedure established by the JADIS rules;
6. Exchange data with registers and other government information systems;
7. Exchange data on beneficiaries of legal entities and collective investment entities through the European Central Platform

Who is the beneficiary to be reported in the list of beneficiaries of the JADIS Beneficiaries subsystem (JANGIS)?

Important: The full definition of a Beneficiary is given in Article 2, Part 14 of the Law on the Prevention of Money Laundering and Terrorist Financing (https://e-seimas.lrs.lt/portal/legalActEditions/lt/TAD/TAIS.41300 ?faces-redirect=true) of the Republic of Lithuania. The definition of a beneficiary and its indication in the list of beneficiaries are presented in the scope of the functionality implemented in the JADIS beneficiary subsystem. All rules for determining a beneficiary can be found in the JADIS regulations.

The beneficiary of a Lithuanian legal entity is:

1. A direct owner (a direct owner is an individual who owns 25 percent and one share or more than 25 percent of the client’s ownership interest). If there is a direct owner, it is necessary to indicate “the degree of ownership rights (shares, deposits and/or voting rights) owned by the direct owner (percentage amount)”.
2. An individual who controls a legal entity in other ways, when this person is not the direct owner of the legal entity. Control methods can be:
3. 1. The right to make strategic decisions and/or control a legal entity:
   2.1.1. The right to appoint and/or dismiss the head of the legal entity and/or members of the management board (or other collegial management body);
   2.1.2. The right to approve the annual financial report on the payment of dividends;
   2.1.3. The right to veto decisions of management bodies legal entity;
   2.2. Other ways of managing a legal entity through close relatives, other personal or business relationships;
   2.3. The possibility of using or receiving other benefits from property and/or activities belonging to a legal entity.
   3. If persons specified in 1-2 are not identified, the beneficiaries are all individuals who control the legal entity for other rights:
   3.1. Head of the legal entity,
   3.2. Chairman of the management board (or other collegial management body),
   3.3. Member of the management board (or other collegial management body),
   3.4. Others (senior manager) – an official or employee holding a sufficiently high position who has sufficient knowledge about the risk of money laundering and/or terrorist financing arising for an institution or company, and is responsible for making decisions that may affect on the emerging risk.

When declaring the beneficiaries of a legal entity, the following basic rules are observed:

1. The owners are announced who own more than 25% of shares, deposits and/or votes in a legal entity, depending on the organizational and legal form of the legal entity. If the organizational and legal form of a legal entity provides for control over assets and votes, the percentage of both forms of management or at least one of these forms of management is more than 25%, then the number of assets and votes is declared as a percentage.
2. The beneficiaries are declared who control the legal entity in other ways.
3. In case of absence of owners and beneficiaries controlling the legal entity in other ways that meet the criteria described above (see paragraphs 1 and 2), all persons controlling the legal entity on other rights are declared.
4. A person directly controlling a legal entity can be represented only once, that is, the same individual can be declared the owner or beneficiary, controlling in another way or having other rights only once.

The accountant of Company in Lithuania UAB will be happy to answer additional questions and accompany you in the process of adding beneficiaries of your Lithuanian company to JADIS (JANGIS).