The launch of the Central Register of Beneficial Ownership has been delayed.
There will be an extended time-frame to make beneficial ownership filings with the Companies Registration Office following the launch of the Central Register of Beneficial Ownership which is now expected to be launched in Q4 2017.
The European Union Fourth Anti-Money Laundering Directive is now due to be enacted in Q4 2017, however certain provisions have already been transposed into Irish law.
In accordance with these provisions all Irish companies / entities are required to maintain a register of beneficial owners.
The register of beneficial owners will contain accurate and current information with respect to individuals who directly or indirectly hold a legal / beneficial interest in a company / entity or an individual who has control over the affairs of the company / entity.
As a result all Irish companies/entities are obliged to make enquiries to identify beneficial owners of their company, issue the appropriate notices to any person identified as a beneficial owner, and create a Register of Beneficial Owners.
In addition it is expected that companies/entities will be obliged to make submissions to the Registrar of Beneficial Ownership of Companies and Industrial and Provident Societies, once appointed. This is the first step in creating a central register of beneficial owners of Irish registered companies/entities which will ultimately allow banks and various other institutions carrying out customer due diligence access to up-to-date information on the beneficial owners of companies/entities.
Our Corporate Compliance Department is available help in taking the next steps to ensure compliance with the obligations in relation to disclosure of beneficial ownership.
We can advise Irish companies on the measures to be taken to obtain the relevant information, to create and maintain a register of beneficial owners and make the appropriate submissions to the Registrar of Beneficial Ownership of Companies and Industrial and Provident Societies where required.