Anti-money laundering (AML)
Are you up to date with AML requirements?
- The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA), which became effective from 15 July 2010 and transposed the Third AML Directive into Irish law.
- Core AML guidelines applicable to all financial services designated persons. Deloitte assisted in the development of these guidelines.
See also Final AML guidelines and the risk based approach.
- Sectoral guidance notes for credit unions.
- Sectoral guidance notes for the life assurance industry.
Deloitte recommends a six-step approach to ensure you and your business are AML compliant.
Six steps to compliance
- Carry out a risk assessment of your products/services, customers, geographical jurisdictions and sales channels
- Consider application of the new risk-based approach
- Identify exemptions and use simplified due diligence where possible
- Implement new policies and procedures to manage “Politically Exposed Persons”
- Make arrangements for reliance on third parties
- Update all your documentation
Are you ready for further changes?
- The CJA Amendment Bill 2013, the primary purpose of which is to amend the CJA to align certain provisions more closely with international standards and to amend some provisions to reflect operational requirements (in this regard, however, it is important to note that s. 55 of the CJA (which concerns the keeping of records within the State) remains unchanged by the Bill);
- The Proposal for the 4th AML Directive, which will update the 3rd AML Directive and which proposes to expand the provisions dealing with PEPs to include both domestic and foreign politically exposed persons.
How we can help
We have unrivalled expertise and are helping many clients with various aspects of their AML programmes.We can:
- Draft/review AML implementation strategy
- Design and facilitate a risk assessment workshop
- Develop/review AML policies and procedures
- Deliver training to compliance staff or all client facing staff
- Provide other ad hoc assistance as required
Contact us
Sinead Ovenden
Director, Regulatory Compliance Services
T + 353 1 417 2545