Other ‘designated persons’[1] may look to a client's solicitor with a view to satisfying compliance with their own anti-money laundering obligations. The risk relating to reliance by designated persons on third parties to satisfy their own anti-money laundering requirements remains with the designated person. Designated persons will have different requirements which they require to be fulfilled to satisfy their internal respective policies and procedures.

A company must provide a designated person with the following information where it enters into an occasional transaction[2] with a designated person, or forms a business relationship with a designated person:

• information about its legal ownership, including information on its beneficial ownership;

• information identifying all the beneficial owners of the relevant entity; and

• notification of any change to that entity's beneficial ownership register that occurs which is relevant to the occasional transaction or that occurs during the course of the business relationship formed, and the date on which it occurred within 14 days from the date on which the relevant entity becomes aware of the change.[3]

Next chapter: What is a Beneficial Owner

[1] Including for example a financial or credit institution, accountant, tax adviser. S. 25 of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021.

[2] Reg. 5(9), SI 110 of 2019 - an “occasional transaction” means a transaction in relation to which the designated person is required to apply customer due diligence measures under Part 4 of the Act.

[3] Reg. 8, SI 110 of 2019.