The Central Bank of Ireland has issued a ‘Dear CEO’ letter with respect to compliance by SPVs which are required to be registered under Section 108A of the Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010, as amended, as Schedule 2 firms.
The Central Bank conducts supervisory engagements on an ongoing basis with these entities, and this letter issued has provided an overview of findings identified throughout the course of these supervisory engagements, and it also outlines the expectations from the Central Bank as to the areas that need to be monitored closely.
The main areas of concern are outlined as follows:
– Board oversight and Governance;
– Money Laundering and Terrorist Financing Risk Assessments;
– AML/CFT Policies and Procedures;
– Customer Due Diligence;
– Politically Exposed Persons and Financial Sanctions;
– Suspicious Transaction Reporting; and
For information on how we can assist with the specific findings and expectations of the Central Bank please do get in touch with: