ANTI-MONEY LAUNDERING
On 5 June 2015, the Fourth Money Laundering Directive
(Directive 2015/849/EU) and the revised Wire Transfer
Regulation (Regulation (EU) 2015/847) were published in
the Official Journal. For further information, see our recent
briefing
here.
In May 2015, the Central Bank also published a report on
anti-money laundering (AML), counter terrorism
financing and financial sanctions in the credit union sector,
finding that while good practices were observed,
"widespread and common deficiencies" regarding
compliance with the Criminal Justice (Money Laundering and
Terrorist Financing) Act 2010 (as amended) (CJA
2010) were also discovered. Particular issues identified
included lack of oversight at board level, inadequate customer due
diligence policies and procedures, failure to adhere to policies,
engaging in non-standard practices and failure to provide
appropriate training. Credit unions will be required to confirm
annually that they have put in