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ARTICLE · 11 FEBRUARY 2015

Observations From Recent AML/CTF Themed Inspections

Dillon Eustace
Dillon Eustace
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Dillon Eustace

Dillon Eustace

Dillon Eustace is one of Ireland’s leading law firms focusing on asset management and investment...

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The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 came into effect on 15 July 2010 and was amended by the Criminal Justice Act 2013.

IrelandCorporate/Commercial Law

Introduction

The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the "2010 Act") came into effect on 15 July 2010 and was amended by the Criminal Justice Act 2013 (the "2013 Act") (together the "Act"). The Act transposes the Third Money Laundering Directive (2005/60/EC) and it's Implementing Directive (2006/70/EC) into Irish Law. Designated persons under the Act, including all credit and financial institutions (as defined in the Act) are required to comply with their obligations under the Act.

On 25 February 2014, the Central Bank of Ireland (the "Central Bank") published its planned series of Themed Reviews and Inspections, along with its Enforcement Priorities. This included the Central Bank's intention to conduct a further round of themed inspections in the area of anti-money laundering and counter terrorist financing ("AML/CTF") and the controls which designated persons are required to put in place to mitigate against the risk of

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