Last month the CBI published guidelines on its expectations regarding the AML/CTF obligations of firms following the full transposition of 4MLD;

CBI AML/CTF Guidelines for the Financial Sector

Campbell O’Connor was fined in May 2019 for failures to conduct an appropriate ML/TF risk assessment, inadequate policies and procedures to prevent ML/TF, failure to monitor and scrutinize customer transactions, failure to train staff on identifying suspicious transactions and outsourcing failures.

CBI fines Dublin-based stock broker 280,000 EUR for AML/CTF failures

An alarming increasing number of vulnerable young women are recruited by criminal gangs at music festivals to launder money through online applications and their own bank accounts. Irish banks report an average of 1,600 cases of money muling per year;

Dozens of young people duped into ML scheme at Irish music festivals

Credit institutions, MiFID investment firms, e-money institutions and payment institutions must maintain a register of outsourcing agreements that can be made available to the regulator on request and new arrangements must meet the European Banking Authority (‘EBA’) Guidelines by the end of 2020.

Outsourcing function, not responsibility

Allegedly BOI accounts were used to launder $300m by US lawyer, Mark S Scott, as part of the OneCoin crypto-currency multi-billion dollar scam;

Bank of Ireland Accounts Handled $300m of OneCoin Funds

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