Dear CEO Letter

 

Kathy Jacobs, President, Association of Compliance Officers Ireland (ACOI)

While the letter is addressed to Schedule 2 firms specifically, with all such Central Bank of Ireland communications, it includes sensible reminders for all regulated financial service providers. Familiar themes which the Central Bank has addressed in previous letters and industry reports, and indeed enforcement actions, are being flagged once again.

There are some very useful pointers in terms of the CBI’s expectations, which firms should build into their processes. Of particular interest is the intersection of AML and Outsourcing risks where the responsibility for compliance is always with the regulated firm which must have their own frameworks and policies in place to demonstrate compliance. The importance of the business wide risk assessment is again highlighted today. This was given specific legal backing in the Criminal Justice (Money Laundering and Terrorist Financing ) Act 2018 in this Dear CEO Letter and also comprehensive coverage of Customer Due Diligence requirements.

Whether a Schedule 2 firm or other regulated financial service providers, there is much for organisations to take away from today’s publication, and to reflect on when reviewing and strengthening their AML / CTF frameworks.

 

Dear CEO Letter