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New Regulations on beneficial ownership of express trusts

Thursday, 15th July 2021
New Regulations on beneficial ownership of express trusts

The European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 came into operation on 24 April 2021. The Regulations apply a similar beneficial ownership regime to express trusts, as already applies to corporates and certain other entities (such as UCITS) by way of previously published beneficial ownership regulations.

The Regulations require express trusts to keep internal beneficial ownership registers (an obligation carried over from 2019 regulations) and to file beneficial ownership information to a Central Register, which will be overseen by the Revenue Commissioners. Revenue is in the process of finalising this Central Register, which is due to open for filings on 26 July 2021. Existing trusts within scope of the Regulation will have until 23 October 2021 to file their beneficial ownership information.  

In this briefing we take a detailed look at the Regulations and the implications for trustees of express trusts who must comply with them.

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  • Picture of Sinead  Prunty
    Sinead Prunty
    Knowledge Lawyer, Financial Regulation
      Sinéad is a Knowledge Lawyer in A&L Goodbody's Financial Regulation and Investigations Team. Sinéad joined us from the Enforcement and Anti-Money Laundering Directorate of the Central Bank of Ireland and specialises in financial regulation, compliance and the Administrative Sanctions Procedure.
  • Picture of Anne O'Neill
    Anne O'Neill
    Senior Knowledge Executive
    Anne joined the firm in January 2017. As Senior Knowledge Executive, she supports the firm’s Corporate and M&A group by producing internal know how, tracking legal and regulatory developments and assisting with complex research and legal queries.
  • Picture of Paula Reid
    Paula Reid
    Partner, Knowledge
    Paula Reid is a Partner in A&L Goodbody's Knowledge Team. The firm was the first law firm in Ireland to establish a dedicated knowledge function and partner within its practice, signifying the firm’s commitment to placing knowledge at the forefront of its business.