The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 were brought into effect on 15 November 2016. The Regulations require Irish companies to obtain and maintain accurate information in respect of their beneficial owners and to put a beneficial ownership register in place from this date.
All companies will have an obligation to file information with the Companies Registration Office (CRO) who will hold a Central Register of Beneficial Ownership. The CRO had planned to have their systems in place for this Central Register of Beneficial Ownership to be populated from 26 June 2017, however they have now advised that they will not be ready to receive this information until Q4 2017.
It is anticipated that there will be a period of three months after the launch date during which companies will be able to file their beneficial ownership information with the CRO without being in breach of their statutory obligation to do so.
Further information will be provided by the CRO closer to September 2017 but companies should ensure that they have taken the necessary steps to identify their beneficial owners and put their internal register of beneficial ownership in place so as to be ready in advance the requirement to file this information with the CRO.
If you would like guidance in understanding your obligations in relation to populating the Central Register of Beneficial Ownership, please contact a member of our Audit team.