If you’ve been involved in the funds industry, you will be well aware of the ever-increasing focus on anti-money laundering and “know your customer” requirements by national and supranational regulatory bodies alike. In fact, the Central Bank of Ireland (Central Bank) has consistently listed anti-money laundering as an enforcement priority every year since 2012.

A new addition to these obligations is the implementation of the European Union (Anti-Money Laundering: Beneficial Ownership and Corporate Entities) Regulations 2016 (Regulations), which implemented Article 30 of the Fourth Anti-Money Laundering Directive EU 2015/849 (4 AMLD) and which took effect in Ireland on 15 November 2016. As of that date, all companies and legal entities established in Ireland (Companies and each a Company) are required to take all reasonable steps to gather and maintain adequate, accurate and current information of their “beneficial owners” on an internal beneficial owner register (Internal Register).