Beneficial Ownership Register: Update and Actions Required

The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 (the “Regulations”) (see our previous briefing here) have come into force as of 15 November 2016.

Immediate Action Required

In a move that will come as a surprise to most Irish incorporated companies and other legal entities (“Corporates”), the Department of Finance have opted to implement the Regulations with immediate effect without having undertaken any meaningful consultation on, or forewarning to industry of, these requirements.

This approach has had the effect of forcing the vast majority of Corporates into an immediate technical breach of the Regulations and now requires Corporates to take prompt action to comply with the Regulations.

Any in-scope Corporate (ie the vast majority of Corporates) is now required to take immediate steps to prepare a register (the “Register”) that holds adequate, accurate and current information in respect of its beneficial owners.


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