Central Bank of Ireland - Anti-Money Laundering Bulletin for the Funds Sector

Having recently conducted a number of anti-money laundering, counter financing of terrorism and financial sanctions (“AML/CFT/FS”) supervisory engagements with Funds and Fund Management Companies (“Firms”), the Central Bank of Ireland (“CBI”) has published a bulletin (the “Bulletin”) which details its findings and expectations across the following key areas:
  • Corporate Governance;
  • AML/CFT/FS Business Risk Assessment;
  • Outsourced AML/CFT/FS Activities; and
  • Customer Due Diligence.

While the Bulletin focusses on issues in the Funds sector, the CBI has clarified that it expects all firms, irrespective of their sector, to critically assess their AML/CFT/FS frameworks against the CBI expectations as set out in the Bulletin. The CBI has indicated that it will continue to conduct supervisory engagements with Firms and expects Firms to be in a position to demonstrate that they have reviewed the findings and expectations detailed in the Bulletin against their AML/CFT/FS frameworks and have taken steps to remediate any identified gaps/weaknesses.

We have included a summary below of the key CBI findings for each area together with details of the key CBI expectations. We have also set out some suggested next steps for Firms in order to address the CBI’s expectations.

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