With one week to go until the Register of Beneficial Owners ("RBO") filing deadline on 22 November 2019, it has been confirmed that there will be no extension to this deadline.
To date, a significant number of companies have not made filings with the Central Register, which leaves a large number of companies yet to submit accurate particulars. Whilst companies have received reminders from the RBO on the impending deadline it should be noted that filings made within the next week may be slowed down by the fact that the information has to be matched to the Department of Employment Affairs & Social Protection (DEASP) together with the expected volumes, which may result in submissions not being processed before the deadline.
Although the RBO has stated that after the deadline they will again write to companies to remind them of their requirement to submit their filing, it is important to be cognisant of the fact that the RBO has the power to impose sanctions on companies that are in breach of their obligations. We are not aware as to what form these sanctions will take or how they may be imposed however the legislation is clear on the significant fines that may be imposed for non-compliance.
The primary reasons for the rejection of submissions are:-
- Incorrect PPS number or date of birth;
- Mismatch on first name or surname;
- Middle name not required according to the RBO and if you enter the middle name in either the first name or surname then it may be rejected
In order to avoid a rejected submission, we would suggest if any beneficial owner is unsure of their personal details held with the DEASP, these be checked prior to submission by following the link: Welfare.ie
If you have not addressed the obligations of the Regulations there is still time to do so. The Corporate Compliance team at RBK have significant experience and knowledge on this legislation and will be able to assist by adopting an efficient approach to your company structure. In addition, we can assist with entering the information into the Internal Beneficial Ownership Register of the Company together with filing the Central Register of Beneficial Owners.
If you have any queries on the above or require clarification on the Regulations, please contact Suzanne Tonra, Corporate Consultant, Donna Carey, Corporate Compliance Manager or Catherine Sweeney, Corporate Consultancy Manager on (090) 6480600.