Compliance Ireland Newsletter - July 2017
Seminar Announcment

 

Invitation to Seminar for Credit Unions

Compliance Ireland will host two Full Day Seminars for Credit Unions to include the following sessions:

 Anti-Moneylaundering and Countering Terrorist FInancing UPDATE

Data Protection - Prepartion for the GDPR

Outsourcing - Compliant Arrangements 


Athlone
- 16th August 2017 @9am - Hodson Bay Hotel

Cork - 24th August 2017 @9am - Rochestown Park Hotel

To register your interest, simply email bookings@complianceireland.com

 

Central Bank News
Central Credit Register
Reporting Obligation for Lenders


The Central Credit Register (CCR) went live on Friday, 30th June 2017. From that date on, the CCR will be collecting and storing personal and credit information from lenders about all loans they give to customers over €500.

  

The CCR was provided for under the Credit Reporting Act 2013 as a result of the EU/IMF Programme of Financial Support for Ireland and the Central Bank of Ireland has responsibility for maintaining this new centralised register.


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Financial Crime
Busy in Europe as ESA's and Commission release AML/CFT Risk Reports


The 26th June 2017 was the transposition date for the 4th EU AML Directive and while a number of Member States did not meet that deadline, including Ireland, that did not stop a flurry of activity at European level last week with both the European Commission and the European Supervisory Authorities (EBA, EIOPA & ESMA) publishing AML/CFT Risk Reports. While we await transposing legislation, firms should be familiarising themselves with these documents and fully addressing the highlighted risk factors for your sector. At the very least, it is recommended that these documents are referenced in internal risk assessments.  

Under the 4th EU AMLD, a number of Risk Assessments are mandated: 

Firstly, as under the 3rd Directive, individual Obligated Entities (or Designated Persons in Irish law) are required to have a business wide Risk Assessment which assesses AML & CFT Risks relevant to the business. Little change here, except that going forward this risk assessment should refer to and take into account the other mandated risk assessment documents at the next levels.

 


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Enforcement
AML/CFT Enforcement Continues with Bank of Ireland Sanctioned

On 28th May 2017, the Central Bank of Ireland announced that it had fined The Governor and Company of the Bank of Ireland (‘BOI’) €3,150,000 and reprimanded it for twelve breaches of the Criminal Justice (Money Laundering & Terrorist Financing) Act, 2010. The CBI investigation identified significant failures in BOI’s anti-money laundering and counter terrorist financing (‘AML/CFT’) controls, policies and procedures. The breaches persisted on average for over three years and included failures by BOI relating to:

  • Risk assessment: assessment of money laundering/terrorist financing (‘ML/TF’) risks specific to its business and the relevant mitigating systems and controls.
    • 2012 risk assessment was inadequate as the risk rating for certain categories of customers, products and channels was not included in every instance although that information was identified as necessary for the evaluation of risk for those categories.
    • 2012 and 2013 risk assessments did not address geographical and sectoral risks.

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Data Protection & Privacy
GDPR - Are You Ready or Will You Be?
An Overview of the General Data Protection Regulations

GDPR is Coming! For some May 2018 seems like a long way away, for others it may feel like its approaching at the speed of light. Being aware of the changes and the challenges in trying to prepare and implement significant change to meet the new requirements and to be ready on time can feel daunting for many. This article highlights the significant changes with some pointers on actions needed to comply. We recommend that Firms take action to be ready now rather than waiting until implementation date.


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Compliance Ireland in the Media and at Conferences
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Follow us for seminar and public training announcements and relevant news on Regulatory updates for a host of topics in particular:

  • Irish and European financial legislation & regulation
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06 July 2017
In This Issue
Central Bank News
Central Credit Register
Financial Crime
Busy in Europe as ESA's and Commission release AML/CFT Risk Reports
Enforcement
AML/CFT Enforcement Continues with Bank of Ireland Sanctioned
Data Protection & Privacy
GDPR - Are You Ready or Will You Be?
Compliance Ireland in the Media and at Conferences
Follow us on Twitter!
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