Anti-Money Laundering – Domestic And European Developments

Anti-money laundering and counter terrorist financing ("AML / CTF") remains a key priority for the Central Bank of Ireland (the "Central Bank") and has been listed as an enforcement priority every year (including this year) since 2011 when the Central Bank published its first ever list of enforcement priorities.  The Central Bank will continue this focus in 2015 ahead of the mutual evaluation of Ireland by the Financial Action Task Force which is expected in Q4 2016.

The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended by the Criminal Justice Act 2013 (the "CJA"), requires "designated persons" to implement policies, procedures and controls to detect and prevent money laundering and terrorist financing.  Compliance with the CJA is a legally enforceable obligation, breaches of which are subject to criminal and / or administrative sanctions.  The importance, therefore, of fully and effectively implementing the requirements in the CJA