The issues identified, which are set out in the Report, include:
Incomplete risk assessments that do not effectively consider the inherent Money Laundering/Terrorist Financing risks relevant to the bank;
Risk assessments undertaken are very high level and lack thorough analysis of key risks;
Failure to include AML/CFT reviews in annual monitoring and internal audit plans;
Deficiencies in the Politically Exposed Persons process, including initial screening, the timing of Senior Management approval and the failure to sufficiently identify, verify and document Source of Funds and Source of Wealth data;
Non-adherence to stated AML/CFT and FS policies;
Failure to ensure the provision of appropriate and comprehensive training to Board and committee members, as well as enhanced training for staff in key AML/CFT and FS roles;
Shortcomings in relation to the coverage and the timing of automated screening of customer databases for FS purposes.
The Report reflects the importance placed by the Central Bank on the role of governance in robust AML/CFT compliance and provides some interesting messages for boards and senior management of relevant regulated businesses.
While the Report is based on inspections conducted across the banking sector the Central Bank has stated that many of the issues raised in the report are relevant to the broader financial services sector in Ireland.
For further information please contact any member of the A&L Goodbody's Anti-Money Laundering Unit.