The Central Bank of Ireland has published the results of its assessment of the compliance of Schedule 2 Firms with the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010). This “Dear CEO” letter is meant to communicate to firms the Central Bank’s expectations in regard to AML/CFT and Financial Sanctions (FS) requirements as well as the actions CEOs and Boards should take in response to the results of the assessment.
The assessment revealed an overall lack of compliance across all areas of the AML/CFT framework. Many firms lack an adequate awareness of what Board and senior management need to do under their AML/CFT obligations. Moreover, Schedule 2 Firms fail to demonstrate Board supervision of AML/CFT and FS, lack thorough ML/TF risk assessment, and fail to develop, implement or update firm-specific AML/CFT and FS procedures.
Therefore, the Central Bank of Ireland expects all firms to be aware of the ML/TF risks that they face. It also requires CEOs and Boards to have in-depth knowledge and understanding of their AML/CFT obligations. All firms must also have adequate AML/CFT framework in place to protect not only their business but also their customers. Additionally, firms must determine if they need to register with the Central Bank under Schedule 2.
Source: Central Bank of Ireland