Public statement relating to an enforcement action against E-Services and Communications Credit Union Limited

Date26 October 2018
Enforcement Action
The Central Bank of Ireland
E-Services and Communications Credit Union Limited
E-Services and Communications Credit Union Limited fined €155,000 by the Central Bank of Ireland in
respect of a contravention of Section 21 of Central Bank Reform Act 2010
On 24 October 2018, the Central Bank of Ireland (the “Central Bank”) imposed on E-Services &
Communications Credit Union Limited (“E-Services”) a fine of €155,000 and reprimanded it for a
contravention of regulatory requirements contained in Section 21 of Central Bank Reform Act 2010 (the
2010 Act”). The contravention was admitted by E-Services and the enforcement action has been
concluded by way of settlement agreement between the parties.
A Fitness and Probity (“F&P”) regime for credit unions came into effect on 1 August 2013 and was
implemented on a phased basis. The regime imposes regulatory standards on individuals performing
influential and custo mer facing roles, designated ‘controlled functions’ (“CFs”). The Fitness and Probity
Standards for Credit Unions (the “Standards”) have applied to all CF holders in E-Services since 1 August
2014. The regime further imposes obligations on credit unions themselves to not allow individuals to
perform CFs unless they are “satisfied on reasonable grounds” that the individuals meet the Standards
and have agreed that they will abide by the Standards.
The Central Bank’s investigation identified three separate breaches in relation to E-Services’ F&P
requirements. Two breaches occurred over a period of three years and three months. One breach
occurred over a period of three years and five months.
During these periods, E-Services failed to:
Introduce adequate systems or controls to ensure full compliance with its F&P obligations;
Take all reasonable steps to carry out adequate F&P due diligence on individuals performing CFs;
Ensure that certain employees and an outsourced internal audit service provider complied with
and agreed to abide by the F&P Standards.
The breaches came to light as a result of a Themed Inspection carried out by the Central Bank. Following
the inspection the Central Bank issued a Risk Mitigation Programme (“RMP”) to E-Services detailing the
deficiencies identified, as well as the remedial actions required. An aggravating feature in the case was a

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