Sir, – The Register of Beneficial Owners (RBO) opened on July 29th (five weeks after the originally announced date of June 22nd); however, the filing deadline of November 22nd has remained unchanged.
Whilst the legislation provided for the appointment of a Registrar of Beneficial Ownership this function was given to the Companies Registration Office.
As the RBO has not been linked to the existing data filed with the Companies Registration Office, the only means of complying with the legislation is to log-in to the portal www.rbo.gov.ie and complete the filing; it is not being linked to the web-based self-service CORE portal or other software providers, nor can the information be provided by post or email.
The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016 came into effect on November 15th, 2016, and relevant entities were required to maintain an internal register of their beneficial owners (the Beneficial Ownership Register), also known as PSC (People with Significant Control).
Therefore all this information does exist and is readily available for submission by upload or other means. I reckon the cost to relevant entities and their presenters of using the current RBO portal to be in excess of €2 million.
The failure of the RBO to engage with the legal, accounting and secretarial professions to permit the use of existing software (as is the case with the Companies Registration Office) puts a massive burden and cost on the 200,000 legal entities that are obligated to file and maintain this register either directly or through their presenters.
These coming four months are also the peak months for filing both Companies Registration Office returns and Revenue returns.
There is no helpline or contact telephone number, so if you encounter any difficulties you have to email enquiries@rbo.gov.ie.
Given that literally every company and society is legally obliged to file such comprehensive information within the next four months, I believe that greater support and interaction are required on the part of both the Government and the Register of Beneficial Owners. – Yours, etc,
EUGENE
HAYES,
Midwest Corporate
Services Ltd,
Chartered Secretaries
in Public Practice,
Limerick.