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.
The Regulations apply with effect from 15 November 2016 and there are no savers or transitional periods. Accordingly, any (re)insurer in scope is required to:
- 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”.
For more information, please view our full briefing here or speak to your usual William Fry contact.
Contributed by: Niall Campbell