The organic charge-transfer salt $kappa$-(BEDT-TTF)$_{2}$Hg(SCN)$_{2}$Br is a quasi two-dimensional metal with a half-filled conduction band at ambient conditions. When cooled below $T=80$ K it undergoes a pronounced transition to an insulating phase where the resistivity increases many orders of magnitude. In order to elucidate the nature of this metal-insulator transition we have performed comprehensive transport, dielectric and optical investigations. The findings are compared with other dimerized $kappa$-(BEDT-TTF) salts, in particular the Cl-analogue, where a charge-order transition takes place at $T_{rm CO}=30$ K.