Central Bank Publishes Report on AML, CTF and Sanctions Compliance in Banks
On the 17th February 2015 the Central Bank published a report on Anti-Money Laundering, Counter Terrorist Financing and Financial Sanctions compliance in Banks in Ireland.
Head of Anti-Money Laundering, Domhnall Cullinan said: "The Central Bank acknowledges that satisfactory processes and controls were found in place in some areas. However, the number and nature of issues identified suggests that more work is required by banks in Ireland to effectively manage Money Laundering and Terrorist Financing risk. While the banking sector in Ireland is the specific focus of the report, many of the issues raised are relevant to the broader financial services sector in Ireland." As such, the Central Bank expects all financial and credit institutions to carefully consider the issues raised in the report, and to use the report to inform the development of AML/CFT and FS frameworks.
The issues identified include:
The report sets out separate areas where issues arose and also helpfully identifies specific expectations that the Central Bank has with respect to how these areas should be dealt with.
- Incomplete risk assessments that do not effectively consider the inherent Money Laundering/Terrorist Financing risks relevant to the bank;
- Risk assessments undertaken are very high level and lack thorough analysis of key risks;
- Failure to include AML/CFT reviews in annual monitoring and internal audit plans;
- Deficiencies in the Politically Exposed Persons process, including initial screening, the timing of Senior Management approval and the failure to sufficiently identify, verify and document Source of Funds and Source of Wealth data;
- Non-adherence to stated AML/CFT and FS policies;
- Failure to ensure the provision of appropriate and comprehensive training to Board and committee members, as well as enhanced training for staff in key AML/CFT and FS roles;
- Shortcomings in relation to the coverage and the timing of automated screening of customer databases for FS purposes.
You can access the full report here. Compliance Ireland highly recommends that you read it in full