Register of Beneficial Ownership – Annual Report 2021

PUBLISHED: 10th October 2022

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The Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO) has published its annual report for 2021 which states that at the end of 2021, 87% of companies and 73% of societies had filed their beneficial ownership information.

The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 came into force on 23 April 2021.   It requires all ‘designated persons’ (e.g., banks, financial institutions and other service providers) to inspect the RBO as part of their customer due diligence process before establishing a business relationship with a customer; and to report any discrepancies and non-compliance to the Registrar. As a consequence of these new requirements, the number of searches of the RBO and the purchase of RBO reports increased significantly in 2021 compared to 2020.

In 2021, the RBO also introduced two new forms for reporting Discrepancies and the Registrar continues to issue non-compliance to those entities that have failed to disclose their beneficial ownership information.
Failure to maintain an adequate, accurate and current internal register of beneficial owners of a reporting entity and/or failure to comply with filing requirements may result in:

•    On summary conviction, a Class A fine not greater and €5,000; or

•    On conviction on indictment, a fine not exceeding €500,000.

If you require assistance or advice in relation to any of the above matters, please contact our experienced Company Secretarial and Corporate Governance team.

Colm Hanley at
Michelle Howe at
Patricia Kelly  at
Meadhbh Nolan at  

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