What this means is that public searches can no longer be obtained. This may affect your business in the following ways:
- If you need to obtain this information on a customer under your Anti-Money Laundering obligations.
- If you are engaging with a professional service provider as this information must be provided.
- If you are opening a bank account or seeking other services (e,g, insurance cover) from a financial institution as this information must be provided.
The suspension of the search facility does not suspend the requirement to obtain appropriate information on the ultimate beneficial owner of any clients. Nor does it suspend the requirement to update your company information on the RBO with any changes as filings can still be made.
During the period of suspension, companies must continue conducting their own investigations into beneficial ownership using relevant information or data obtained from a reliable and independent source and keep records of the actions taken during the verification process. As soon as the access to the RBO data is reinstated, an excerpt from the RBO should be obtained and compared to the results of their findings.
The RBO are currently working on providing access for Designated Persons only (e.g. financial institutions, auditors, tax advisers, legal professionals, property service providers and dealers in expensive goods such as houses, cars, jewellery, art works, etc.).
Our experienced advisors at Evelyn Partners can provide advice and assistance in creating and maintaining internal Beneficial Ownership Registers and making appropriate filings. If you would like further information on how we can help, please contact our Company Secretarial Lead at Richard.firstname.lastname@example.org
A copy of the ECJ Press Release can be found here: ECJ Press Release.