UBO Documentation Post-SEBI May 2024. The New Compliance Layer SEBI's May 2024 circular tightened UBO (Ultimate Beneficial Owner) disclosure requirements for FPIs. The key threshold: any natural person holding more than 25% economic interest or voting rights in the FPI entity must be identified as a UBO and
If you are a CA or CS firm handling foreign investor registrations, you already know the broad strokes: FPI registration goes through a Designated Depository Participant, the client needs notarized and apostilled documents, and SEBI's KYC framework governs what's acceptable. What this guide covers is the
There is a specific moment when this becomes a problem. A board resolution from the company’s Delaware subsidiary is submitted for a RoC annual filing. The Registrar’s office returns it. The document is not apostilled. The CS firm managing the compliance checks the previous year’s filing. The
The wire has landed. The investment agreement is signed. Your startup client has received foreign capital, and now the FEMA clock is running. You have 30 days from the date of receipt of funds to file Form FCGPR with the RBI. That filing requires the foreign investor’s apostilled KYC.
Your company got the ISIN. You appointed the RTA. The depository is ready. On paper, you are compliant with the MCA’s dematerialisation mandate. Then your foreign shareholder’s KYC application came back rejected. And then it came back rejected again. This is unfortunately not an unusual situation. It is