AILO warns advisers: unregistered UK trusts will delay offshore bond transactions

The Association of International Life Offices (AILO) is urging advisers and trustees to ensure that UK trusts holding Irish-issued life policies are registered on Ireland’s Central Register of Beneficial Ownership of Trusts (CRBOT) well in advance of any policy transaction. 

The warning follows earlier engagement by AILO and industry partners with Irish Revenue and regulators regarding the practical challenges associated with registering UK and non-EU trusts on CRBOT. 

While those discussions initially focused on the absence of a workable registration process, technical solutions have now been introduced enabling non-Irish trustees to register on the Irish trust register. 

However, AILO is warning that trustees who attempt transactions without completing registration beforehand are likely to face delays, as Irish financial institutions must first verify CRBOT registration as part of their anti-money laundering obligations. 

Marie Hainge, Chair of AILO’s Legal & Regulatory Committee, said: 

“Our earlier engagement with Irish authorities focused on ensuring a workable registration process for UK and other non-EU trusts. 

With registration now possible, the focus must shift to awareness and action. Advisers should ensure their trustee clients register well before they need to transact.” 

Under Irish anti-money laundering legislation, many UK express trusts holding Irish situs assets — including life assurance policies issued from Ireland — are required to register on CRBOT, even where they are already registered on the UK Trust Registration Service. 

Jonathan Hall, Legal Executive at AILO, added: 

“We are particularly concerned about situations where trustees only become aware of the requirement when they attempt time-critical transactions such as policy surrenders or assignments. 

At that point, registration will need to be completed before the transaction can proceed, which could delay access to funds.” 

AILO is therefore encouraging advisers and trustees to review affected trust structures and complete CRBOT registration in advance of any future policy transactions. Remembering that some trusts, such as pension schemes, may also need to be registered even if exempt in the UK under the TRS. 

In addition, if the trust is administered in the EU (trustees are there), then it will be exempt from registration in Ireland. For example, this will exempt Malta-based QROPS schemes. 

The CRBOT registration portal is available here: https://www.revenue.ie/en/crbot/index.aspx 

AILO’s Legal & Regulatory Committee will continue to engage with regulators and provide guidance to the sector as implementation develops.