If you’re a trustee of a trust with any connection to Ireland, you may be legally required to register that trust with the Central Register of Beneficial Ownership of Trusts (CRBOT). This obligation is part of Ireland’s anti-money laundering framework and is designed to improve transparency around who ultimately owns and controls trusts.
What Is CRBOT?
CRBOT is Ireland’s central register for beneficial ownership of trusts, established under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. It supports efforts to prevent financial crime by making trust ownership more transparent. Even if your trust is already registered with HMRC’s Trust Registration Service in the UK, it may still need to be registered with CRBOT if it has Irish connections.
When Must Trustees Register a Trust with CRBOT?
You must register if:
- Trustees are resident in Ireland
- The trust is administered in Ireland
- The trust owns land or property in Ireland
- A trustee enters into a business relationship in Ireland on behalf of the trust
- This includes trusts that hold bonds issued by Irish financial institutions, such as Standard Life, Prudential, Canada Life, Utmost, Aviva, or M&G, to name but a few.
Key Deadlines
- Trusts established on or before 23 April 2021 were required to register by 23 October 2021.
- Trusts established after 23 April 2021 must register within six months of their creation.
- While Revenue has acknowledged technical difficulties for some UK trustees and has shown flexibility, trustees should not delay registration. Failure to comply can result in:
- Fines of up to €500,000
- Imprisonment of up to 12 months, depending on the offence
Trustees’ Responsibilities
As a trustee, you are personally responsible for:
- Determining whether your trust is in scope
- Registering the trust via Ireland’s CRBOT portal
- Providing accurate information about all beneficial owners
- Keeping the register updated if there are changes
- Beneficial owners include:
- Trustees
- Settlors
- Beneficiaries
- Anyone with control over the trust
Practical Steps for Trustees
- Review your trust’s structure and assets for any Irish connections
- Check correspondence from investment providers for Irish-issued bonds
- Seek professional advice if you’re unsure whether registration is required
- Act promptly to avoid penalties
Trustees have a duty to uphold transparency and comply with legal obligations. Registering with CRBOT is not just a regulatory requirement, it’s a reflection of your commitment to good governance and responsible stewardship. If your trust has any Irish links, check your obligations and register as required.
For assistance in reviewing a trust’s requirements under CRBOT, or with registering the trust itself, please contact us.