Financial Crime World

Ireland’s Financial Sector Faces Heightened Risk of Money Laundering and Terrorist Financing

Ireland’s Central Bank has issued updated guidelines for financial institutions operating in the country to strengthen anti-money laundering (AML) and counter-terrorism financing (CFT) measures.

Key Changes to Enhance Risk Assessment, Customer Due Diligence, Transaction Monitoring, and Suspicious Transaction Reporting

  • Emphasis on firms conducting business relationships with customers who deliberately avoid face-to-face contact for reasons other than convenience or incapacity. Firms are required to flag such customers as potential risk factors.
  • Requirement for financial institutions to perform customer due diligence (CDD) whenever they are obliged by law to contact a customer to review relevant information related to the beneficial owner connected with the customer.
  • Need to keep CDD information and documents up-to-date, including any external or environmental factors that may impact risk. This includes pandemic-related factors, which have become increasingly important in today’s global landscape.

Transaction Monitoring Requirements

  • Firms must monitor at least four customer transactions to identify suspicious activity using automated systems or manual controls, depending on their specific business activities and customer profiles.
  • Emphasis on connectivity between customer identification and verification, transaction monitoring, and suspicious transaction reporting processes.

Reporting Suspicious Transactions

  • Firms must submit suspicious transaction reports (STRs) to the Irish Revenue Commissioners using Revenue’s Online Service (ROS).
  • Firms are required to register for ROS.

Employee Training

  • Emphasis on employee training, which must include:
    • Training on business risk assessments and how they impact daily work
    • Internal reporting procedures
    • Whistleblowing policies
    • Escalation procedures

Compliance Requirements

  • Firms will need to review their existing governance arrangements, processes, and policies to ensure compliance with the updated guidelines.

Additional Resources

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