As part of the transposition of the Fourth Anti-Money Laundering Directive (EU 2015/849) ("4MLD"), Irish companies and other legal structures such as trusts and collective investment vehicles will for the first time be obliged to;

  • maintain details of their underlying beneficial owners and
  • report the details to a central register which will be accessible to regulators and other certain other interested parties.

It is expected that the first phase of this initiative will come into effect this month, when a statutory instrument (the "S.I.") will be signed into law requiring entities within scope ("Obliged Entities") to start maintaining beneficial ownership data in their own internal registers. The obligation to report to a central register is unlikely to come into effect until 4MLD is fully transposed which is expected to occur in June 2017.

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