As you may be aware from our previous William Fry update, the Department of Finance published the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 (the "Regulations") on 15 November 2016.
The Regulations require companies and other legal entities incorporated in Ireland to take all reasonable steps to hold adequate, accurate and current information on their "beneficial owners" on an internal beneficial ownership register.
- Establish an internal register of their beneficial owners
- Where the beneficial owners are not known, take "all reasonable steps" to ensure the beneficial ownership information is obtained and entered on the beneficial ownership register
- Where no beneficial owners can be identified, enter the names of the senior managers of the relevant entity on the beneficial ownership register as the "beneficial owners".