Are you writing plans in trust?

Helen Huijsdens
Helen Huijsdens, Compliance Specialist
Monday, 21st February 2022

The bill to transpose the fifth Anti-Money Laundering Directive (5AMLD) into national law was signed on 18th March 2021 and the commencement order signed by the Minister for Justice on 23rd April 2021. The directive requires all EU member states to establish a Central Register of Beneficial Ownership of Trusts (CRBOT). The purpose of the CRBOT is to help prevent money laundering and terrorist financing by improving transparency of who ultimately owns and controls Irish trusts.

The 2021 regulations require the trustees of certain trusts to file beneficial ownership information in the Central Register of Beneficial Ownership of Trusts (the CRBOT). Revenue will operate the CRBOT and has established a trust register portal on Revenue’s Online Service (ROS) to facilitate registrations. Trustees can register on the CRBOT through a trust register portal on Revenue’s Online Service (ROS). Revenue also provides information on how to register.

Certain trusts are exempt from these requirements, including: 

  • Approved occupational pension schemes
  • Approved retirement funds
  • Approved profit-sharing schemes or employee share ownership trusts
  • trusts for restricted shares
  • The Haemophilia HIV Trust
  • Unit trusts

Irish Life's flexible trust forms have been updated to reflect the new requirements and Advisory Services has produced a guidance document on trusts.

If you have any questions about what to expect if you are writing an Irish Life plan in trust, or if you have written a plan in trust previously, please contact your account manager who will be able to help you.