Our advisors can assist your organisation with its compliance as is required under Anti-Money Laundering (“AML”) and Counter-Financing of Terrorism (“CFT”) legislation.
Certain entities are subject to AML/CFT regulations as covered by The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended by Part 2 of the Criminal Justice Act 2013 (“the Act”). If your business is included in the types of persons classified as a “designated person” under Section 25 of the Act, then we can help you with your compliance.
Transaction Monitoring – Credit Unions
We provide bespoke Transaction Monitoring Reports for Credit Unions. Talk to us about how we can save your Credit Union time and money by providing consolidated reports for transaction monitoring.
Are you finding that your staff are spending too much time working through numerous spreadsheets downloaded from your database before they can even begin looking at transactions? This is a common complaint and we have a solution for you. Here’s how it works.
We work with you to identify your criteria for the transactions you wish to monitor and provide you with expert advice with regard to tackling your AML compliance. Then we can start on building a bespoke report for your Credit Union. This is not an “off the shelf” package, we will work with you at the outset to ensure that the final report we provide suits the needs of your Credit Union.
What You Do
- Download the relevant reports and save them to a secure online share file location.
What We Do
- Check any changes to high-risk jurisdictions.
- Verify that all criteria are correct as per your specifications.
- Upload your reports to our system.
- Run the criteria-based automation.
- Consolidate all data into one user friendly report.
- Check that all relevant data has been included.
- Save the final report to the secure online share file location.
Then It’s Back To You
Your staff can then work through the final consolidated report to assess the transactions identified.
All work will be carried out to the high standards we hold ourselves to as Chartered Certified Accountants with comprehensive checks completed prior to us issuing the final report. We will stand over all reports and can provide confirmations in this regard as required for internal or Central Bank audits.
A Service Agreement (also containing a Data Processing Agreement) will be signed in advance of any data being shared.
General AML Compliance – How can we help
Below is a short summary of what organisations are required to have in place under the law. However, we have found that some just need a bit of guidance and assistance to ensure that they are fully compliant with their obligations. From preparing the initial risk assessment to implementing polices, controls and procedures and carrying out in-house training, we can help you through the steps involved.
Business Risk Assessment
Under the Act, all organisations, no matter what size, must complete a Business Risk Assessment (“BRA”). A well thought out BRA is essential as this informs an organisation’s due diligence measures and documents the risk determination process. It also dictates the appropriate policies, controls and procedures (“PCPs”) needed to combat the risks identified.
Organisations are required to carry out ongoing monitoring of all business relationships on a regular basis. This involves the scrutiny of transactions, including where necessary, the source of funds, to ensure they are consistent with the organisation’s knowledge of the client, their business and risk profile. Periodic client reviews should be carried out, as well as identifying key trigger events that will require an updated client risk review.
Customer Due Diligence
Under the law, it is a requirement for designated persons to carry out Customer Due Diligence (“CDD”) when doing regulated work. Sufficient evidence should be obtained to establish that a real person or organisation is being dealt with, and this evidence should be used to assess the risk that the client might be involved in AML activities, or might seek to use your organisation to assist them in this activity. CDD can be simplified or enhanced depending on the risk level identified in your BRA
Policies Controls and Procedures
The obligation of organisations to ensure that they adopt appropriate Policies Controls and Procedures (“PCPs”) is explicitly referred to in the Act. Effective AML compliance for any organisation must include the implementation of controls that increase the chances of detecting and preventing money laundering. In order to identify, assess, monitor and manage the risks, the PCPs should be designed to suit the level of risk.
Suspicious Transaction Reports
Organisations are required to prepare a Suspicious Transaction Report (“STR”) in any instance where an organisation encounters actions which are inconsistent with a client’s known legitimate business or personal activities or with the normal business for the type of client. Organisations are legally obliged to report any actual or suspected instances of money laundering to the Financial Intelligence Unit (“FIU”) of An Garda Síochána and Revenue.
The Act also puts an emphasis on training and making sure that all staff are aware of the obligations of the organisation, and them as employees, in relation to compliance with AML/CFT legislation. Specific and regular training is required.
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Under the Beneficial Ownership of Corporate Entities Regulations 2016, most corporate and other legal entities incorporated in a Member State are now required to “obtain and hold adequate, accurate and current information on their beneficial ownership”.