Anti-Money Laundering/Counter-Terrorism Financing

Author:Ms Paula Kelleher
Profession:Dillon Eustace

(i) Central Bank Inspections

The Central Bank is currently in the process of carrying out on-site inspections to confirm that certain companies (including funds) are in compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, (the "CJA 2010"), particularly with respect to the customer due diligence obligations and internal policies and procedures including training.

In advance of the inspection, companies are required to provide (among other matters) the following:

details in relation to the list of new customers since 15 July 2010; confirm those customers who have not been fully identified and verified in accordance with the CJA 2010; confirm those who have been verified by a relevant third party; provide copies of policies and procedures to prevent and detect money laundering and terrorist financing; and provide copies of board minutes for the last two years. (ii) Central Bank Instructions on EU Financial Sanctions

On 24 August 2011 the Central Bank, as the Competent Authority responsible for the administration and enforcement of EU Financial Sanctions, issued Instructions to institutions, requiring them, for example, to:

examine their records and confirm to it on or before 1 November 2011 whether they have any funds or economic resources in the name of any person, group or entity currently the subject of EU restrictive measures; provide the Central Bank with details of any funds and economic resources, belonging to, owned or held by such persons which the institutions have frozen; bring any name(s), so discovered, to the attention of the Garda Bureau of Fraud Investigation; and have adequate systems and controls in place to ensure compliance with their obligations under financial sanctions legislation including (a) screening new clients against current restrictive measures and (b) screening customer databases on an ongoing basis for compliance with prevailing restrictive measures. Persons who fail to comply with an Instruction issued by the Central Bank are liable on conviction to imprisonment and/or a fine.

All correspondence with the Central Bank in relation to the information requested above should be addressed to:

Financial Sanctions Unit, Enforcement, Central Bank of Ireland, Block D, Iveagh Court, Harcourt Road, Dublin 2. Email:

The Central Bank's Financial Sanctions Notification August 2011, which includes information on outstanding financial sanctions-related...

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