Settlement Notice - Swilly Mulroy Credit Union (Sanctions confirmed by the High Court)

• Date: 02 July 2025

Central Bank of Ireland

Administrative Sanctions Procedure

Settlement Notice

To: Swilly Mulroy Credit Union (“Swilly Mulroy”)

Date: 1 July 2025

Part 1. Action

1. For the reasons set out in this Settlement Notice, the Cent ral Bank is publishing a

statement pursuant to Section 33BC(2) of the Central Bank Act 1942, as amended

(the 1942 Act), concerning sanctions imposed on Swilly Mulroy for contraventions

of the Criminal Justice (Money Laundering a nd Terrorist Financing) Act 2010 (the

2010 Act), and the Credi t Union Act 1997, as amended (the 1997 Act), between

January 2014 and June 2021.

2. Swilly Mulroy has agreed to the facts in Part 2 (the Undisputed Facts) and admitted

the prescribed contraventions in Part 3 of this Settlement Notice, such that further

investigation is unnecessary.1 On this basis, the Central Ba nk has decided that it is

appropriate to impose the following sanctions:

 a reprimand;

 a monetary penalty of €51,819 with the application of a 30% settlement

scheme discount bringing the amount to €36,273.

1 Section 33AR(1)(a)(ii) of the 1942 Act: “where there are undisputed facts that in the reasonable opinion of the

Bank render an investigation unnecessary, suspects on re asonable grounds that a person is committing or has

committed a prescribed contravention…”

2

3. Swilly Mulroy has agreed to these sanctions,2 however they will not take effect

unless confirmed by the High Court.3

4. Further detail on the contraventions and sanctions are set out in Parts 3 and 4 of

this Settlement Notice.

Summary of Reasons for the Central Bank’s acti on

5. Swilly Mulroy is a community based credit union, which has operated from March

1985 to present and is authorised and regulated under the 1997 Act and continued

to be authorised during the period of the prescribed contraventions. Swilly Mulroy

was subject to the requirements of the 2010 Act for the period of the prescribed

contraventions.

6. The 2010 Act requires credit unions to comply with their Anti-Money

Laundering/Counter Financing of Terrorism (AML/CFT) obligations by ensuring

that they conduct, amongst other things, the required levels of Customer Due

Diligence (CDD), Transaction Monitoring and that they carry out the necessary

Business and Customer Risk Assessments to prevent and detect the commission of

Money Laundering and Terrorist Financing in respect of the services they provide.

7. The 1997 Act requires credit unions to be well governed and managed, and to have

appropriate risk management systems with such governance arrangements and

systems and controls to allow them to identify, assess, measure, monitor, report

and manage the risks which they are, or might reasonably be, exposed to.

8. The matters that form the background to the Central Bank’s enforcement action

relate to issues identified during an inspection carried out at Swilly Mulroy by the

Central Bank’s Anti-Money Laundering Division in April 2022 (the Inspection).

2 In this case, Swilly Mulroy has also agreed to dispense with an In quiry.

3 Pursuant to Section 33AWA of the 1942 Act.