Since Statutory Instrument SI 110 came into effect in July 2019, certain entities mainly companies and Industrial & Provident Societies) are obliged to register their beneficial ownership details with the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (the RBO).
Since April 2021 a further leg of this AML legislation was enacted under the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 (the Act). The Act requires accountants (among others) to inspect the RBO as part of their Customer Due Diligence (CDD) before establishing a business relationship with a customer, and to report any:
- discrepancies (as defined) and
- non-compliance (as separately defined) to the Registrar.
Some of the statistics from the RBO’s latest Annual Report for 2023 are shown below.
Companies
These statistics indicate that Companies’ compliance rate with this legislation has improved by 1% from 85% in 2022 to 86% in 2023, still leaving almost 42,000 companies (14%) that are not fully compliant with their RBO obligations by 31 December 2023.
| 31/12/2023 | 31/12/2022 | |
| Live companies required to file with the RBO |
299,496 |
280,721 |
| Companies which had registered beneficial owners with RBO |
258,241 |
239,444 |
| Compliance rate in % terms | 86% | 85% |
Societies
Likewise Industrial &Provident Societies also improved their compliance rate by 1% from 74% in 2022 to 75% in 2023, still leaving 239 societies (or 25%) that are not fully compliant with their RBO obligations at the end of 2023.
| 31/12/2023 | 31/12/2022 | |
| Live societies required to file with the RBO |
941 |
949 |
| Societies which had registered beneficial owners with RBO |
702 |
698 |
| Compliance rate in % terms | 75% | 74% |
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
- Our latest CPD Webinar on The Main Changes in Irish GAAP (recorded July 2024)
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion you receive a CPD certificate for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
