Compliance Update

Tue Aug 20 2019

Reminder:  AML Survey – Central Bank of Ireland

The Central Bank have written to intermediaries conducting a short survey of the Retail Intermediaries sector to determine the extent of products currently being sold that are subject to the requirements of the CJA 2010.  The aim of this survey is to determine what proportion of Brokers are handling premiums and advising on investments which would be deemed higher risk from an AML/CTF aspect.  Inspections going forward will then be focused on higher risk intermediaries.   The survey should be completed and returned to the Central Bank by the 31st of August.

Beneficial Ownership Register – Action Required by all incorporated members

Note:  These requirements do not affect members who are partnerships or sole traders

In March 2019, the Minister for Finance signed into law Statutory Instrument No 110 of 2019 to establish a Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (the RBO).  The registrar of Companies was appointed as the Registrar of Beneficial Ownership of Companies and Industrial & Provident Societies with effect from the 29th of July 2019.

The new register (the RBO) opened for filings on Monday the 29th of July.   All incorporated members are required to take action in relation to this new requirement. Filing of beneficial ownership data can only be made on-line through a portal on the RBO website at  A user ID and password is required to log in. This can be set up at the time of registering beneficial ownerships – see

There are no paper forms and no filing fees involved.

Companies have until Friday the 22nd of November to file their data with the RBO without being in breach of their statutory duty to file.

Note:  The returned information will only be in respect of the member firm unless an agreement is in place that the member firm will make a return for a client company. 

Brokers Ireland in conjunction with Midwest Corporate Services Limited have drafted guidance for members in relation to the requirements which is available in the AML/CTF folder in the members compliance section on the website.

Midwest Corporate Services Limited, Suite A2, No.1 Charlotte Quay, Limerick are independent and specialist providers of company secretarial and corporate governance services to company directors, accountants and solicitors.


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