Central Bank Report On AML In The Irish Funds Sector

On 18 November 2015, the Central Bank issued a report setting out its observations and expectations in relation to Anti-Money Laundering ("AML"), Countering the Financing of Terrorism ("CFT") and Financial Sanctions ("FS") compliance by Irish funds and fund service providers (each, a "firm"). The report is based on a series of inspections both on and off site that were carried out over the course of 2014. The inspections included: (i) a review of relevant AML policies and procedures, risk assessments and management information; (ii) interviews with key senior staff, including Money Laundering Reporting Officers ("MLROs"); (iii) sample testing of customer due diligence ("CDD") documentation, suspicious transaction reports, third party and outsourcing arrangements, transaction monitoring records and training records; and (iv) testing of IT systems and controls, including measures relating to screening of investors for compliance with FS regulations.