INTRODUCTION:
New European anti-money laundering legislation requires each member state to
maintain a central register to record the beneficial ownership information of
‘Relevant Trusts’. In the 26 Counties, this is called the ‘Central Register of Beneficial
Ownership of Trusts (CRBOT)’ and is being hosted and managed by the Revenue
Commissioners.
The Revenue Commissioners have met with the GAA at the Central level to highlight the
new legal obligations for all our GAA/LGFA/Camogie and Handball clubs along with
County and Provincial units who are, in legal terms, deemed to be ‘Relevant Trusts’.
GAA clubs are now required to record the details of their trustees and executives on this new register which can be completed via Foireann.
- Further guidance is available at www.revenue.ie/en/crbot.
- Please send any queries to Trustregister@revenue.ie
- If you have specific GAA queries, please send them to GAAtrustregister@gaa.ie and not foireann@gaa.ie as they will not be able to assist.
ADMIN FAQs:
WHO IS REQUIRED TO FILE THIS INFORMATION?
Any member who is assigned to a position on the Executive Committee including custom/club-specific positions.
WHO HAS ACCESS TO THIS INFORMATION?
Designated persons (i.e. financial institution, Auditor, legal professional) are now required to check that the beneficial ownership information has been included on the register (CRBOT) before establishing a business relationship. This means that where clubs are seeking loan finance or have an engagement with their solicitor, then the lender and/or solicitor are obliged to check that the trust is recorded in the CRBOT before commencing the loan or taking on the engagement. This will also arise as part of the annual audit of accounts by auditors. CRBOT is also open to Gardaí, Revenue Commissioners, and the Criminal Assets Bureau.
Failure to supply this information will likely hinder future banking transactions and may potentially leave designated trustees liable for a financial penalty.
HOW DO I REPORT ON THIS TO SEE WHO HAS PROVIDED THE INFORMATION?
You cannot see any of the information they provided i.e specific details , however as a club admin, you can generate a report on your club to see who has supplied the information via Foireann.
To generate this report, please navigate to the Administration Section > Report Tab and here, you should see a CRBOT Compliance Detailed Report.
As mentioned above, you cannot see the specific details the member has entered, but you can determine from the report if they have completed the form or not.
A MEMBER HAS PROVIDED THE INFORMATION OUTSIDE OF FOIREANN, HOW DO I UPLOAD THIS TO THEIR PROFILE?
If a member has provided the information via an alternative method outside of Foireann such as ROS or via www.revenue.ie then your club will just need to keep a separate record of these members. There is no way for you to update this on Foireann to indicate that the member has uploaded this information elsewhere.
It is important to note that you keep a separate note of this as your reports on Foireann will not be accurate.
CAN I UPLOAD THIS INFORMATION ON BEHALF OF A MEMBER?
No, the member has to upload this information themselves. If they do not wish to upload it to Foireann or if they do not have a login to Foireann, then they can file the information through ROS or my account on www.revenue.ie.
HOW DO I GET MY CLUB CRBOT NUMBER?
CRBOT numbers for clubs will only be issued once information has been submitted to Revenue.
All club executive and club trustee information will be sent through to Revenue in May 2023 after the membership deadline closes.
Therefore clubs will not be given a CRBOT number until after May 2023, if not later in the year.
Any questions on this, please contact GAAtrustregister@gaa.ie
HOW DO MEMBERS FILL OUT THIS INFORMATION?
Please see the guide outlined below on how your club members can upload this information to Foireann:
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