The Central Bank of Ireland has launched its Guidelines on Anti-Money Laundering and Countering the Financing of Terrorism ("AML/CFT") for the financial sector ("Guidelines"). The Guidelines are available here and follow a consultation process (CP128) initiated in December 2018.

The Guidelines are welcome, coming after the substantive implementation of the Fourth Money Laundering Directive into Irish law in November 2018. Firms should now review their policies and procedures to ensure they are line with the Guidelines.

As firms digest the new Guidelines, attention will soon turn to implementation of the Fifth Money Laundering Directive which is due for transposition into Irish law in January 2020. The Sixth Money Laundering Directive is also due for implementation in 2020.

In her speech announcing the Guidelines, Derville Rowland (Central Bank Director General, Financial Conduct) confirmed that the Guidelines will operate as a live document and will be updated as new obligations come into force.

The speech highlights the Central Bank:

- carried out 72 on-site inspections, held 59 review meetings and issued 259 “Risk Evaluation Questionnaires” to firms last year; and

- has taken 12 enforcement actions against credit and financial institutions in relation to breaches of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 - imposing fines of €12.5 million to date.

This reflects focus found elsewhere in the EU, where substantial sanctions have been imposed. It is clear that AML/CFT has been high on the list of priorities for the Central Bank and this is expected to continue as the legislative landscape continues to evolve. 

In particular, the speech highlights transaction monitoring as a key supervisory priority for the Central Bank - there is a warning of the danger of having "blind faith" in automatic systems.

Please reach out to me, my regulatory colleagues Eoin O'Connor or Shane Martin, or your usual Walkers contact for more information.