As part of the new European Union’s policy against money laundering, all trustees of the Dutch pension funds will have to register as “ultimate beneficial owners” UBOs and tax authorities, the police and public prosecutor have access to the register. According to Wopke Hoekstra, it may be impossible for pension funds to accommodate individuals who qualified as UBOs based on interests as an owner, voting rights or right to say; however, to avoid a situation where a UBO at a pension fund is unable to be clearly identified, all board members are compelled to be registered as a “pseudo UBO”. Although more clarification is still needed to know if pension fund trustees qualified as UBOs. This was criticized by the Pensions Federation and was considered to be an unnecessary burden on the administration of the Federation.
