On 9 November 2021, the Central Bank of Ireland ("Central Bank") published the latest edition of its Anti-Money Laundering Bulletin (the "Bulletin"). The Bulletin details the findings and subsequent expectations arising from the Central Bank's AntiMoney Laundering / Counter Financing of Terrorism / Financial Sanctions ("AML / CFT / FS") supervisory engagements with funds and fund management companies ("Firms") in the following areas of compliance:

  • Corporate Governance;
  • AML / CFT / FS Business Risk Assessment;
  • Outsourced AML / CFT / FS Activities; and
  • Customer Due Diligence.

While the supervisory engagement focused on the funds industry, the Central Bank states that Designated Persons1 operating in other sectors of the financial services industry should also take note of the Bulletin and consider its relevance to their firm / sector.

The below table captures the key findings and expectations set out by the Central Bank in the Bulletin.

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