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Statement of the nature & extent of interest held:.The following information is required for each Beneficial Owner: The requirement for corporate and legal entities ("companies/societies") to hold their own beneficial ownership register was transposed into Irish law by Statutory Instrument No 110 of 2019. If in doubt, a company/society should seek legal advice to assist it in establishing who its beneficial owners are.

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Relevant entities shall keep records of the actions taken to identify their beneficial owners (Regulation 5(5), SI 110/2019) If, after having exhausted all possible means and provided there are no grounds for suspicion, no natural person is identified as a beneficial owner, or if there is any doubt that the person(s) identified are the beneficial owner(s), the natural person(s) who hold the position of senior managing official(s) shall be recorded on the RBO as the beneficial owner. The name of another company/society cannot be entered on the RBO. Ultimately, it is a natural person(s) who must be identified and entered on the RBO as the beneficial owner(s) of the relevant entity, irrespective of how many layers of ownership there are in the company/society’s structure.

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If a relevant entity is a subsidiary owned by multiple corporate entities, Article 3(6), 4AMLD, states that a shareholding of 25% plus one share or an ownership interest of more than 25% in a subsidiary held by multiple corporate entities which are under the control of the same natural person(s), shall be an indication of indirect beneficial ownership. If a relevant entity is a subsidiary owned by another corporate entity, any natural person(s) who holds or controls a shareholding of 25% plus one share, or an ownership interest of more than 25% in the parent corporate entity, is a beneficial owner(s) of the subsidiary. the power to appoint senior management”.

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“Control through other means may, inter alia, include the criteria of control used for the purpose of preparing consolidated financial statements, such as

  • control via other means which is explained in Recital 13 of 4AMLD as follows:.
  • controlling (directly or indirectly) more than 25% of the company/society’s voting rights,.
  • ownership (directly or indirectly) of more than 25% of the company/society’s shares,.
  • A Beneficial Owner is defined in Article 3(6), 4AMLD, as any natural person(s) who ultimately owns or controls a legal entity, either through direct or indirect ownership of a sufficient percentage of the shares or voting rights or ownership interest in the entity, including through bearer shareholdings, or through control via other means.







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