The concept of “beneficial owner of enterprises” (BO) is first officially introduced and clearly defined in the Law amending and supplementing a number of articles of the Law on Enterprises 76/2025/QH15 (Amended Law on Enterprises 2025). This law imposes several obligations on enterprises relating to BO, including declaration of BO information and disclosure of data necessary for BO identification. In parallel, the applicable anti-money laundering law also stipulates the responsibilities of lawyers and law-practicing organizations in updating and verifying client identification information during their provision of legal services. Therefore, in the context of the current legal framework, lawyers and law-practicing organizations can not only support businesses in implementing BO-related compliance obligations, but also fulfill their own responsibilities under the laws on anti-money laundering, with particulars including:
(i) Responsibility to assist enterprises in identifying their BO based on reliable sources of information;
(ii) Responsibility to assist enterprises in identifying whether or not they are required to declare, notify, and retain BO information;
(iii) Responsibility to assist enterprises in determining the timing of BO declaration, reporting, and information retention.
