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ARTICLE · 12 FEBRUARY 2021

Irish SPVS And Schedule 2 AML Compliance Obligations

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On 16 December 2020, the CBI issued a "Dear CEO" letter highlighting AML compliance issues that Irish SPVs that are Schedule 2 Firms (so-called because they carry out one or more of the activities specified in Schedule 2 ...

IrelandGovernment, Public Sector
Turlough Galvin
Turlough Galvin
Alan Keating
Alan Keating
Richard Kelly
Richard Kelly
Joe Beashel
Joe Beashel
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On 16 December 2020, the Central Bank of Ireland ("CBI") issued a "Dear CEO" letter (the "Letter") highlighting anti-money laundering ("AML") compliance issues that Irish SPVs that are Schedule 2 Firms (so-called because they carry out one or more of the activities specified in Schedule 2 of the Criminal Justice Act 2010) should be monitoring with care. Schedule 2 Firms would include, for example, Irish SPVs that are involved in activities such as lending, debt factoring or finance leasing.

Appendix A to the Letter sets out the CBI's findings, as well as its expectations, in various categories.

Board Oversight and Governance

Firms should be able to demonstrate that AML is a regular agenda item at meetings of the board of directors (the "Board") and that they have a framework in place for monitoring and identifying updates to relevant legislation. They must have a process in place to ensure timely updates to their framework to ensure on-going compliance.

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