Following recent parliamentary amendments to the Republic of the Marshall Islands (RMI) Associations Law (the “Associations Law”), all RMI active corporation formation agents are advised to pay particular attention to the new recordkeeping requirements for bearer shares.
All corporations issuing bearer shares must now use all reasonable efforts to keep up-to-date records of all holders and beneficial owners of bearer shares as well as any subsequent transfers. For all bearer shares issued before the enactment date of the law, there is a phase-in period of 360 days, ending in November 2018.
These records must be recorded with the corporation’s registered agent in the RMI, in order to maintain the validity of the bearer share.
Bearer share information may be recorded by completing the Declaration of Holders and Beneficial Owners of Bearer Shares or the Declaration of Transfer of Bearer Shares.
A detailed advisory note on recordkeeping requirements arising from the November 2017 amendments can be found here.