Once the DoF releases a SI covering what will be adopted from 5AMLD, a central UBO Register for corporate and other legal entities must be established within 18 months of the date of 5AMLD's activation. The period is extended to 20 months after the date in respect of the UBO of trusts.
As aforementioned, it is integral that companies currently have an internal Register of Beneficial Ownership and evidence of how the Ultimate Beneficial Owner was designated. This must be readily available for inspection and be in place ready for the uploading of the Register to the online portal.
Once the online portal is up and running, there is likely to be a period of six months for legal entities to file online (no fee) their Register of Beneficial Ownership without being in breach of their obligations.
We recommend that companies reach out to their corporate service provider with any queries and ensure the necessary steps have been taken to comply with legislation and avoid penalties.