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Definition timely manner12/10/2023 On receipt of this e-mail, the RBO will provide the appointed RBO Liaison Officer(s) for that organisation with a DN1 form and details on how to upload the DN1 to the RBO Sharefile Account. For data protection reasons, please do not include details of the discrepancy in this e-mail. If you are an authorised officer of a ‘relevant person ’ and you wish to report a discrepancy, please send an email to stating the name of your organisation. The Registrar has determined that a discrepancy shall be reported by a ‘relevant person’ using a Form DN1 and that the DN1 shall be delivered to the Registrar by uploading the form to a secure folder in the RBO’s Sharefile Account. The RBO has contacted all ‘relevant persons’ in relation to the appointment of RBO Liaison Officers who will coordinate reports of discrepancies on behalf of the ‘relevant person’. The term ‘relevant person’ refers to the Garda Síochána, the Revenue Commissioners, the Criminal Assets Bureau or a competent authority. ![]() Only a person who is an authorised officer of a ‘relevant person’ is entitled to report a discrepancy to the Registrar on behalf of a ‘relevant person’. In the case of a ‘ relevant person’, Regulation 26(1) states that if any relevant person forms the opinion that there is a discrepancy between the information relating to a relevant entity in the central register (RBO) and the beneficial ownership information available to the relevant person relating to the same entity, to the extent that it does not interfere unnecessarily with the performance of its functions, the relevant person shall deliver, in a timely manner, to the Registrar, notice of that opinion specifying the particulars of the discrepancy.Ī ‘relevant person’ is a competent authority, the Garda Síochána, the Revenue Commissioners or the Criminal Assets Bureau. ![]() The definition of a ‘designated person’ is provided in Section 25 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended, and includes credit institutions, financial institutions, auditors, external accountants, tax advisors, property service providers, casinos and any person trading in goods involving transactions totalling at least €10,000. In the case of a ‘ designated person’, Regulation 20(3)(b) states that if a designated person carrying out customer due diligence on an entity, or otherwise, forms the opinion that there is a discrepancy between the information in the central register (RBO) and the information the entity must hold in its internal register of beneficial ownership, then the designated person shall deliver, in a timely manner, to the Registrar… notice of that opinion, specifying the particulars as respects which the foregoing discrepancy exists. SI 110/2019 only provides for discrepancies to be reported to the Registrar of Beneficial Ownership by a ‘designated person’ or a ‘competent authority/relevant person’. In the RBO regulations (SI 110 of 2019), a “discrepancy” has a specific meaning given to it and it depends on who is reporting the ‘discrepancy’.
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