ARTICLE · 12 JULY 2023

AML Update: RBO Access Formally Restricted To Those With A Legitimate Interest

Arthur Cox

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By way of reminder, on 22 November 2022 the European Court of Justice announced its finding that the provision of the Fourth Money Laundering Directive (MLD4)...

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Suzanne Kearney

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By way of reminder, on 22 November 2022 the European Court of Justice announced its finding that the provision of the Fourth Money Laundering Directive (MLD4) (as amended by the Fifth Money Laundering Directive (MLD5)) under which Member States must ensure "any member of the general public" can access information held on the central registers of beneficial ownership of corporates is invalid.

Our earlier insights on that decision are here:

AML Update: ECJ decision impacts access to beneficial ownership information (November 2022)

Access is Restricted to Central Register of Beneficial Ownership (January 2023)

Following that decision, and pending EU and/or Irish legislative response, the Irish Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO) significantly restricted the ability to search its records, with only extremely limited information being available to members of the public.

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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