In a previous post we advised of the requirements of The European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 which came into effect on 22 March 2019. It provided for the establishment of a central register of beneficial ownership with effect from 22 June 2019. View post and factsheet.
After a short delay in the launch date in order to finalise a procedure to permit the collection of PPS numbers for beneficial owners, the central register of beneficial ownership and the related online portal opened to accept filings on 29 July 2019.
Existing companies have until 22 November 2019 to ensure their beneficial ownership information is submitted to the central register through the online portal whilst companies incorporated on or after 22 June 2019 have 5 months from the date of incorporation to fulfill their reporting obligations.
Thereafter, any changes to the beneficial ownership of a company must be notified to the central register within 14 days.
Confirmation of identity of individuals not holding a PPS number
Each beneficial owner must provide their PPS number when the internal register of beneficial ownership is being uploaded to the central register so that their identity can be verified.
Those beneficial owners who do not hold a PPS number are obliged to complete and submit a Form BEN2 to verify their name, date of birth, nationality and address. The form must be sworn in the presence of a notary and the signed form uploaded to the online portal. Further details of the process for uploading the information will be made available by the Registrar of Beneficial Ownership in due course.
We are happy to assist and advise you in relation to this statutory requirement. For more information on what you need to do and how we can help, please do not hesitate to contact our Company Secretarial department or your usual Crowe contact.