CRBOT registration - UK trusts

• The Central Register of Beneficial Ownership of Trusts (CRBOT) in Ireland has been set up in accordance with anti-money laundering regulations. It is operated by Irish Revenue.
• UK trusts taking out (or holding) SJP’s international investment products must register with the CRBOT within 6 months.
• This 6-month period begins on the date the trust first takes ownership of an international investment product (for example, the SJP International Investment Bond).

• This is a personal legal obligation on the trustees of the trust. Failure to register can result in fines and/or criminal convictions.
• The trust must be registered on the CRBOT even if (a) it is already registered with the Trust Registration Service in the UK or (b) it is exempt from registration with the Trust Registration Service in the UK.

• SJP’s international investment products are provided by an entity based in Ireland (SJP International Plc). Therefore, any trust investing in those products (including UK trusts) are in scope of the CRBOT regulations.

Details on how to register on the CRBOT can be found here:

• Background information and guidance: https://www.revenue.ie/en/crbot/trusts-that-must-register/non-residents.aspx
• CRBOT registration link: https://ros.ie/online-enquiry-web/nonResidentTrustRegister?execution=e1s1&lang=en
• ‘How To’ videos: https://www.revenue.ie/en/crbot/trusts-that-must-register/videos.aspx
• Queries & support – Irish Revenue: [email protected]

Details of all of the trust’s ‘beneficial owners’ must be registered. This includes the following parties to the trust:

• Settlors
• Trustees
• Protectors (not commonly seen)
• Beneficiaries (either named individuals or a class of beneficiaries)
• Any other person that otherwise controls the trust either directly or indirectly (for example, has powers to add/remove trustees, dispose of trust property or vary the terms of the trust)

Copies of proof of identity (e.g. passport) will need to be provided for all beneficial owners of the trust – refer to the Irish Revenue website & guidance for further details on acceptable documents and how to upload them. 

• After registration, the trustees are legally required to notify the CRBOT of any changes to the details of the beneficial owners of the trust as soon as possible (e.g. if a trustee is added/replaced, settlor changes their address etc). 
• This ongoing requirement remains in place until the trust no longer holds any international investment products.

• If the trust is already on a similar register in another EU Member State, it will be exempt from the requirement to register on the CRBOT. The trustees will need to obtain a certificate from that other EU register and hold a copy on the trust’s records as proof of the exemption.
• Other exemptions from CRBOT registration are also available. However they only relate to trusts set up under specific Irish statutes, so they are unlikely to apply to UK trusts. 

• Note that if any of the trustees of the trust reside in the Republic of Ireland, they must register the trust on the CRBOT even if the trust does not hold an international investment product. 

• Regulators and law enforcement agencies will have ‘unrestricted access’ to a trust’s beneficial owner details on the CRBOT.
• Regulated entities (e.g. banks, insurance companies etc) will have restricted access to this information, as well as persons that can demonstrate a legitimate interest (e.g. investigative journalists researching potential wrongdoing). Access to the information of minors is subject to additional protections.

• For reference, the applicable regulations regarding CRBOT registration are the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021

• If you have questions in relation to a new registration or wish to notify the CRBOT of a change to an existing registration, you can contact Irish Revenue directly at: [email protected]
• Information can also be found on the Irish Revenue website