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Bonnie Tsui

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Bonnie Tsui is a partner in the Transactional Practice Group and joined Baker McKenzie's Toronto office as a summer associate in 2012. She was awarded an International Clerkship in 2014, working with the Global Reorganizations team in the London, England office. Bonnie is Co-Chair of the Student Recruitment Committee for the Toronto office.

Registers of ultimate beneficial ownerships (UBO) are gaining momentum globally, with over 100 countries committed to implementing reforms to UBO regulations.
UBO disclosure and reporting requirements are important for businesses to be familiar with. For employers, understanding their own ownership structure and the transparency rules can mitigate compliance risks and also demonstrate commitment to ethical business conduct.

In June 2019, the Canada Business Corporations Act (CBCA) was amended to require private CBCA corporations to prepare and maintain a register of “individuals with significant control” (the “ISC Register“).
There have been two key changes since this requirement was first introduced:

  1. In May 2023, regulations were published to exempt additional corporations from having to prepare and maintain an ISC Register and to provide further compliance guidance.
  2. Amendments to the CBCA have been enacted imposing, amongst other things, the requirement to publicly file certain information contained in the ISC Register with Corporations Canada and to increase penalties for non compliance.