The law of 13 January 2019 creating the register of beneficial owners: The ambiguous concept of "Senior Managing Official"

The Luxembourg law of 13 January 2019 (the «RBE Law»), creating the register of beneficial owner (the «RBE»), implementing EU Directive 2015/849 on the prevention of the use of the financial system for the purpose of money laundering (“AMLD4”) has created the obligation for all Luxembourg companies registered with the Luxembourg RCS to register the identity of their beneficial owner(s) (each a “BO”).