Ireland: corporate bank account opening
Corporate identity, ownership evidence and account-purpose checks for Irish banks under CJA 2010 and Central Bank guidance.
Ireland · Banks · Central Bank of Ireland
Corporate customers, including overseas companies · Account opening: AML/CDD review
By Matthew Lee
Obtain the company's registered name, number, office, directors and business details. Use the CRO company printout and filings for registered particulars. Obtain incorporation and ownership records from the home jurisdiction for an overseas customer.
Establish owners and account operators
Identify beneficial owners, take reasonable measures to verify their identity and understand the ownership and control structure under section 33 of CJA 2010. Obtain the relevant register of beneficial ownership information where required, alongside shareholder and control records. Record and investigate material differences between the sources.
Verify the person acting for the company and their authority. Request the bank mandate or corporate resolution naming the signatories and the rules for joint instructions. Where a trustee or nominee holds shares, obtain the agreement identifying the relevant rights and parties.
Purpose and higher-risk cases
Section 35 requires information about the purpose and intended nature of the relationship. Record expected receipts, payments and funding; obtain the contracts or financing documents needed to support unusual arrangements, such as another entity collecting the customer's revenue.
Apply the required enhanced measures and PEP approvals where relevant, resolve sanctions findings and complete the verification required before acceptance. Document the basis for any permitted exception to normal verification timing.
Review transactions against the recorded business and update ownership and authority evidence when it changes. CBI guidance calls for reporting qualifying suspicions to both FIU Ireland and the Revenue Commissioners; keep the escalation evidence under restricted access.