Under the amended Law on Enterprises, read with Decree 168/2025/ND-CP, a beneficial owner is an individual who directly or indirectly holds at least a quarter of the charter capital or voting shares, or who otherwise exercises control over the enterprise. A company registering for the first time submits that information as part of its registration dossier. A company registered before 1 July 2025 provides it when it next registers or notifies a change, and subsequent changes are reported to the business registration authority.
For a nominee arrangement this has two consequences. The first is that the arrangement no longer hides the investor from the registrar, so a structure justified to a board on the grounds of confidentiality needs a different justification or a different design. The second is consistency: the beneficial owner named in the registration record, the declaration given to the bank under anti-money laundering rules and the economics described in the cooperation agreement all have to tell the same story. Where they do not, the inconsistency is visible to two different institutions at once.
This is a manageable position rather than a fatal one. It does mean the ownership decision should be made with the disclosure in view from the beginning, which is how we sequence the work: screening and structure comparison first, documentation and declarations prepared together, then registration and banking coordinated from the same file.
