The Registrar of Beneficial Ownership is obliged by law to verify the identity of beneficial owners in order to comply with the EU’s Fourth Anti-Money Laundering Directive that requires the register to be “adequate, accurate and current”.For beneficial owners who do not have a PPSN, the Registrar has determined that the Form BEN2 - Declaration as to Verification of Identity - will be the method used to verify the person’s identity.The BEN2 serves two purposes. It enables the Registrar to verify the identity of a beneficial owner who does not have a PPSN and it is an application for an RBO Number which can be used in all future RBO filings for that person unless he/she obtains a PPSN, in which case the PPSN must be used.The fillable BEN2 form is currently available to download from the RBO Website at www.rbo.gov.ie and from the RBO Portal which can be accessed through the RBO website. The facility to upload the completed BEN2 and apply for an RBO Number is NOW LIVE.Only one BEN2 is required in respect of each beneficial owner and once this has been processed successfully and an RBO Number issued by the Registrar, that RBO Number can be used for making future beneficial ownership filings for that person.
The BEN2 form requires the beneficial owner to sign a statement saying that they do not have a PPS number assigned to them. Any relevant entity that submits a BEN2 application containing such a statement knowing that it is false, commits an offence and is liable to prosecution. For more information visit FAQ No 12 on the RBO website - https://www.rbo.gov.ie/faqs.html. Helpful Hints in relation to the BEN2 form:
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