The Irish Central Register of Beneficial Ownership of Trusts (CRBOT) is a database managed by the Irish Revenue to collect and store information relating to the individuals who are the owners or have a controlling interest in relevant trusts. It is similar in structure to the UK HMRC Trust Registration Service (TRS).

Why is it important, and what does it mean regarding Irish regulations?

The CRBOT was introduced to comply with the fourth and fifth EU Anti-Money Laundering Directives as a preventative measure against financial crimes under the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021.

The CRBOT is a key component of Ireland’s anti-money laundering regime, providing transparency over the beneficial ownership of trusts with Irish connections. The Irish regulations place an obligation on trustees to identify beneficial owners, maintain accurate records and register qualifying trusts. Compliance with these requirements helps demonstrate adherence to Irish anti-money laundering legislation and avoids the penalties that may arise from non-compliance.

Since Brexit, qualifying UK trusts must register on the CRBOT as well as the HMRC Trust Registration Service (TRS), as the TRS does not satisfy EU Trust registration requirements.

When does a trust need to register?

Registration on the CRBOT is required for trusts that have a sufficient connection to Ireland as outlined below:

  • the trust is administered in Ireland
  • a trustee is resident in Ireland
  • the trust acquires land and property in Ireland
  • the trust has an Irish bank account
  • the trust owns Irish investment bonds or life policies
  • the trustee enters into an ongoing business relationship with an Irish regulated service provider.

Newly established qualifying trusts are required to register on the CRBOT within six months of the date that the Irish connection arose. Existing trusts with an Irish connection should register as soon as the trustees become aware that a registration obligation applies.

Trustees are required to maintain the accuracy of the information held on CRBOT. Where any registrable information changes, the register should be updated within six months of the trustees becoming aware of the change.

If you would like to discuss whether a trust you are involved with needs to register, please contact us.