On 16 December, 2020, the Central Bank of Ireland (CBI) issued
a
“Dear CEO” letter to Schedule 2
Firms concerning its findings as regards the compliance of
such firms with Anti-Money Laundering (AML) and
Counter Financing of Terrorism (CFT)
obligations.
The CBI has indicated that the letter serves two purposes;
firstly, it provides an overview of findings identified by the CBI
in the course of supervisory engagements with registered Schedule 2
Firms since January 2020, and secondly, it sets out the
expectations of the CBI in relation to Schedule 2 Firms.
Schedule 2 Firms comprise unregulated firms which carry out
certain financial services activities from an Irish base (e.g.
corporate lending, financial leasing and other activities specified
in Schedule 2 of the Criminal Justice Act 2010). Such firms have
been required to be registered with the CBI for AML/CFT purposes
since 2018.