When Ireland’s regulators began to assess the country’s sprawling ecosystem of special-purpose entities and so-called Section 110 vehicles, their concerns extended beyond questions of tax.  Hidden behind corporate filings and embedded within layers of structured-finance transactions were entities that, while often performing legitimate and economically significant functions, presented heavy challenges for oversight.  In its submission to the Department of Finance’s 2024 Funds Review, the Central Bank of Ireland captured this concern in stark terms.  Special-purpose entities (SPEs), it observed, are “relatively straightforward to establish”, yet their complex structures make them “potentially vulnerable to exploitation for money-laundering purposes”. The Central Bank’s…

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