RBO Annual Report 2020:  Register of Beneficial Ownership

PUBLISHED: 12th August 2021

The Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO) has published its annual report for 2020 which provides insight into the activity of the RBO during 2020 and the rate of compliance by relevant entities in Ireland.

Background

The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 (S.I. 110 of 2019) established the RBO and the Register opened for submissions in July 2019.

All relevant entities existing on 22 June 2019 were obliged to file their beneficial ownership information with the RBO within five months or by 22 November 2019.

Companies formed after 22 June 2019, must make their initial disclosure within five months of their incorporation date and disclosure updates to their beneficial ownership details within 14 days of a change.

Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies Annual Report 2020

The following is a snapshot of the Annual Report 2020

• Nearly 189,000 (81%) of companies and 616 societies (64%) had filed beneficial ownership information with the register by the end of 2020.
• COVID-19 had a significant impact on the number of RBO submissions from March – October 2020.  The Registrar rejected 21% of submissions.
• The RBO issued 7,031 Rejection/GDPR letters to individuals whose personal details were used in failed RBO submissions.
• The RBO received and responded to 12,805 emails.
• A Non-Compliance Reminder campaign was scheduled for March 2020 for all entities that had not filed by the deadline of 22nd November 2019.  It was postponed due to COVID-19, but it began in October 2020 and continued into 2021.
• Non-compliant companies with company numbers between 0 and 499999 were issued with Reminder Notices during 2020. The remainder were scheduled to be contacted in the first quarter of 2021.
• Non-compliant Industrial and Friendly Societies were scheduled to be issued with Reminder Notices in the first quarter of 2021.
• The RBO received seven Non-Compliance Notices relating to entities with no beneficial ownership details filed.
• The RBO received two Discrepancy Notices,  which were subsequently resolved by the end of the year.

We can help

Our Company Secretarial team can assist you in the following ways:

• Outline your obligations under the Regulations in a practical and digestible manner
• Provide advice and training to your organisation
• Review and enhance your internal Register of Beneficial Ownership
• Assist with your initial and ongoing filing obligations to the RBO
• Assist you with responding to a Non-Compliance or Discrepancy Notice from the RBO

Should you wish to discuss our services further or engage us to assist with the various obligations, please contact Colm Hanley at chanley@lkshields.ie or any member of the team at cosec@lkshields.ie