Anti-Money Laundering Reminder


As a reminder to members with regard to Anti Money Laundering, please be aware that the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 was signed into law on the 14th November 2018.  The Act (other than section 32) was commenced on 26th November 2018.  The Act amends the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 to give effect to certain provisions of the 4th AML Directive.

The legislation increases the obligations on a range of entities, such as credit and financial institutions, lawyers, accountants, and high-value goods dealers, in relation to money laundering and terrorist financing. In particular, it imposes requirements on those entities relating to assessing the risks of money laundering and terrorist financing involved in carrying out their businesses; putting policies in place to mitigate that risk; and carrying out customer due diligence measures. It also sets out the functions and powers of the Financial Intelligence Unit of the Garda Síochána.

An explanatory memorandum is available here. Therefore, it is advisable that firms review and update their policies and procedures for this area to take into account the changes.