AML/CFT Guidance Issued by Central Bank of Ireland
New Obligations for Financial Institutions to Enhance Compliance
The Central Bank of Ireland (CBI) has issued updated guidelines for financial institutions to strengthen their anti-money laundering and counter-terrorist financing (AML/CFT) measures. The new guidelines aim to enhance the reporting of contraventions, appoint a member of senior management responsible for compliance, and improve record-keeping practices.
Reporting Contraventions
Financial institutions are now required to have clear internal procedures in place to report contraventions of the Criminal Justice Act 2010 (CJA 2010). The guidelines provide examples of appropriate measures, including:
- An independent internal reporting framework allowing for anonymous reporting
- Staff training on compliance with this reporting obligation
- Clear procedures for identifying and reporting suspicious transactions
Appointing a Member of Senior Management
The CBI has delegated discretion to require financial institutions to appoint a member of senior management responsible for implementing, managing, and overseeing compliance with AML/CFT measures. This individual will be accountable for ensuring that the institution’s AML/CFT program is effective and compliant with regulatory requirements.
Record-Keeping Practices
Financial institutions are required to retain records and evidence of processes and compliance, including:
- Training records
- Documentation of internal reporting procedures
- Accurate and complete records to facilitate oversight and investigation by regulatory authorities
Training and Governance
The updated guidelines also stress the need for regular employee training on AML/CFT measures, business risk assessments, and internal reporting procedures. Financial institutions are expected to conduct thorough training programs to ensure that employees understand their roles and responsibilities in preventing money laundering and terrorist financing.
Next Steps for Firms
Financial institutions must review their existing governance arrangements, processes, and policies to ensure compliance with the updated guidelines. Failure to comply may result in regulatory action, including fines and penalties. The CBI advises financial institutions to seek professional advice on implementing these changes.
The Central Bank of Ireland’s AML/CFT guidelines are effective immediately, and all financial institutions are expected to comply with the new requirements by [insert date].