The Truth About EMA’s UBO Inquiry: Fulfilling Legal Duties, Not Centralising Power

Dear EMA Members,

It has come to my attention that a public statement has been circulated alleging that I “unilaterally requested the registration of the Presidency as the sole Ultimate Beneficial Owner (UBO)” of EMA in the Belgian National Registry. This allegation is false and highly misleading. More importantly, it bypasses both EMA’s internal governance channels and the principles of good faith that should guide our volunteer community.

As President of EMA, it is my legal responsibility and ethical duty to correct this misinformation promptly and transparently, not only to protect the integrity of the office I hold, but also to safeguard EMA's legal standing and credibility. I am therefore issuing this statement to clarify the facts and to prevent further reputational and legal harm to the Association.

Summary

While detailed legal context is provided below, here is a summary of key facts:

• On 20 June 2025, ICF (the Erasmus+ Service Support Team) suggested temporary registration of the President and Vice-President as a procedural compliance step.

• On 7 July 2025, EMA received the grant agreement for its first-ever Erasmus+ Key Action 2 project as Coordinator, with a total budget of €60,000.00, a milestone achievement requiring a timely signature by a legally registered representative.

• On 11 July 2025, I sent a follow-up coordination email to ICF and the newly appointed Management Board (including the Vice-President), seeking updates and alignment on the UBO registration timeline..

• The situation warranting the exploration of a temporary registration of the President and Vice-President as the UBO is the need to sign the newly secured Erasmus+ Key Action 2 project funding as Coordinator, a significant opportunity for EMA. The application for this funding was facilitated by me, in my capacity as former PSU Director. 

• The deadline for signing this contract is 7 October 2025, less than 3 months from now, while the registration of the entire board as UBO will take much longer.

• Based on our records, the registration of all members of the last board (2023-2025) as UBO took almost 18 months.

• The President and Vice-President were proposed for temporary UBO registration because, having already served on the 2023–2025 Board and previously registered as UBOs, their re-registration would be faster and more efficient while the new Board's full registration is processed.

• Without this authorization to sign, albeit temporarily, EMA risks signing the project and losing this project funding.

• At no point was a UBO registration carried out, nor was any action taken unilaterally. The inquiry was purely procedural, coordinated by legal and operational advice from ICF and framed by urgency around a legal deadline.

  
  

Legal Obligation and Timeline

In accordance with Belgian nonprofit law (Article 143 of Belgian law on anti-money laundering), EMA must update its UBO register within one month of any change in legal representation. Per Article 21.2 of the EMA Statute, the previous Management Board’s mandate ended on 30 June 2025, and I assumed the role of President, and thus Legal Representative, on 1 July 2025.

Further, under Article 18.3 of the EMA Statute (2024):

“The President is the primary representative of EMA and is hereby endowed with the power to represent EMA in all respects.”

The responsibilities of the Management Board are clearly outlined under Article 18.1 and 18.2:

“The Management Board is responsible for the daily management, administration and the representation of EMA,” *and must ensure “the facilitation of decision-making efficiency in the Board and the implementation of EMA's strategy.”

My actions were fully in line with these responsibilities.

Urgency Tied to Incoming EU Project

Additionally, without a registered Legal Representative, EMA cannot legally sign agreements, including our first Erasmus+ KA2 project as Coordinator. Without an updated UBO record and legal signatory authority, EMA would be unable to sign the agreement, placing the entire project at risk. My follow-up with ICF on the UBO matter was simply to fulfil this legal obligation and enable the signing process on time.

Coordination with ICF and Legal Advisors

In preparation for the leadership transition, ICF and I (as an incoming President), at the time still part of the management board 2023-25, discussed how to ensure continuity in EMA’s legal and project obligations. The goal was to prevent disruption to ongoing and incoming projects.

On 20 June 2025, ICF shared the following updates:

“We are liaising with BDO regarding updating EMA’s legal registration to reflect the new Board President and Vice President appointments. We've posed the question to BDO whether your current registrations are still valid given that you are both already registered late last year Board members and whether at this stage we can implement a role change without needing to re-register you. If this is possible. We propose taking this approach and will then complete the registration of the other Board members once they are appointed. We will report back as soon as we have further information.”

The inquiry into temporary registration of the President and Vice-President was simply a procedural compliance step to bridge the gap until the new management board members are formally appointed and processed, not an attempt to centralise power.

Misrepresentation and Its Consequences

On 7th July, we received the legal contract of the KA-2 Project, which was issued under the name of the former President, requesting signature from EMA to confirm its acceptance a coordinator of the project. On 11 July 2025, I sent an internal coordination email to ICF titled: “Request for Temporary Administrative Support and UBO/Payment Facilitation”, copying the new EMA Management Board (including the Vice-President), I enquired about further updates regarding the UBO registration. That email was subsequently forwarded outside the board without authorisation, devoid of context, and used to substantiate  a public accusation.

No attempt was made to clarify the facts with me, the legal documentation was not reviewed, and a serious misrepresentation was made public without consulting the full Board.

Call for Reflection

It is deeply concerning that, in an effort to discredit my leadership and portray me as authoritarian, some individuals have chosen to distort  facts and, in doing so, are causing more harm to EMA than good. I urge everyone to reflect on the wider implications of such actions.

Since taking office, I have been focused on rebuilding EMA after a period of neglect, addressing over 500 pending volunteer applications, ensuring proper onboarding of volunteers (including assigning VAs and email credentials), finalising the handover to the new MB, and initiating an internal audit (a legal and operational necessity, especially in light of incoming funds). These were not optional actions, but overdue responsibilities. All these I have tried to achieve, while battling resistance and antagonism. Till date, and despite repeated demands, the outgone president is yet to handover EMA’s official stamp and other necessary financial documentation to me. I have been dedicated to rebuilding EMA, while being distracted by a need to constantly defend myself and the MB against ceaseless misinformation.

I have taken the time to clarify this particular point because the misinformation does not merely affect me personally, it risks compromising the future of EMA itself and every single volunteer and community member.

I invite our community to pause and reflect:  Will you trust the process, or allow yourselves to be swayed by partial narratives? Will you continue to circulate incomplete claims from a small group, or stand with those working to restore the strength and credibility of our association?

Finally, I want to respectfully address the harassment being directed at the experts assisting in the current selection processes. These individuals bring exceptional experience, far greater than any single board, past or present, and have agreed to confidentiality to ensure impartiality and fairness. Once the process is complete, further information will be shared.

Any EMA member who signed or shared the public letter without having full access to the facts is welcome to reach out to me confidentially. We will support any effort to withdraw or clarify positions taken based on partial or misleading information.

Let us be a community that does not just speak about values, but one that lives them.

Now, more than ever, EMA needs unity, integrity, and trust.

Warm regards,

Marvi Qazi

EMA President

More information: Leading Through Transition: A message from the EMA President