The deadline for relevant entities to file their beneficial ownership submissions with the Register of Beneficial Ownership (“RBO”) on the 22nd of November 2019 (which was later extended to the 25th November due to technical faults of the RBO website) has come and gone.

On the 13th of November, just eight working days before the original deadline, only 23% of the companies legally obliged to register with the RBO had done so.

As this register was brought in on foot of EU anti-money laundering legislation2, failure to register on time could result in a €500,000 penalty in the worst-case scenario for Irish businesses.

Additionally, the legislation permits possible imprisonment for up to 12 months for knowingly or recklessly providing false information to the Registrar.

The most common reasons for failed submissions are that one or more of the following details do not match the details held by the Department of Employment Affairs and Social Protection (DEASP): First Name, Last Name, PPSN and/or Date of Birth.

It is therefore vital to ensure that these details are correct and up to date before attempting registration.

The RBO filing obligations are another example of the increasing regulatory requirements facing Irish businesses today.

If you are yet to complete your business’ RBO filing, have any questions regarding your applicability to file, or have queries concerning your broader regulatory requirements, please contact

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