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Corporate beneficial ownership: centrally file by 22 November 2019

22 October 2019

Irish corporate entities (unless exempted) have until 22 November 2019 to register their beneficial ownership information in the Central Register of Beneficial Ownership of Companies and Industrial & Provident Societies (the ‘RBO’).

Background

Since 15 November 2016, certain Irish corporate entities are required to maintain registers containing their respective beneficial ownership information under the EU (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 (the ‘2016 Regulations’). This requirement has been restated and supplemented in the recent EU (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 (the ‘Regulations’).

Part 3 of the Regulations imposes an obligation on relevant entities to file their beneficial ownership information in the Central Register to be maintained by the Registrar of Beneficial Ownership of Companies and Industrial Provident Societies (the 'Registrar'). The Central Register, the RBO, is now in force, and is accepting online filings through the RBO website.

Central Register filing obligation

Timing

Under Part 3, a relevant entity:

  • Incorporated before 22 June 2019 must register its beneficial ownership details in the RBO by 22 November 2019; and
  • Incorporated on or after 22 June 2019 must register its beneficial ownership details in the RBO within 5 months of its date of incorporation.

Information

The beneficial ownership information to be provided to the RBO includes:

  • The relevant entity’s name and number as they appear on the relevant entity’s register (maintained under the Act or the Industrial and Provident Societies Acts, as applicable);
  • Each beneficial owner’s or senior managing officials name, date of birth, nationality, and residential address;
  • A statement of the nature and extent of the interest held, or the nature and extent of control exercised by each beneficial owner; and
  • For verification, the PPS number of each of the relevant entity’s beneficial owners to whom one is issued. Where the person doesn’t hold a PPS number, an RBO Transaction Number must be obtained.

Failure to comply with the Regulations

A relevant entity that fails to comply with its obligations, including failing to deliver the prescribed beneficial ownership information to the Registrar or failing to provide updated information for the purposes of the Central Register, commits an offence and is liable on summary conviction to a class A fine (not greater than €5,000), or on conviction on indictment, to a fine not exceeding €500,000.