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StubbsGazette AML/CFT EBook for Credit Unions


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A comprehensive guide to Anti Money Laundering/Countering the Financing of Terrorism in the Irish Credit Union Sector (also highly relevant to other regulated sectors)

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StubbsGazette AML/CFT EBook for Credit Unions

  1. 1. DO YOU KNOW YOUR MEMBERS? Credit Union Guidance Anti-Money Laundering/ Countering the Financing of Terrorism and Financial Sanctions
  2. 2. Table of Contents Credit Unions and AML/CFT - Reporting Deadline Approaches _________Page 1 AML/CFT/FS – The Background _______________________________________Page 2 Credit Unions and AML/CFT __________________________________________Page 6 Credit Unions and AML Compliance Where we are now _______________Page 9 Risk-Based Approach ______________________________________________Page 11 Senior Management Responsibility and Internal Controls _____________Page 13 Customer Due Diligence (CDD) _____________________________________Page 14 Reporting _________________________________________________________ Page 16 How StubbsGazette Can Help_______________________________________Page 17 Appendix: Glossary ________________________________________________Page 21
  3. 3. Credit Unions and AML/CFT - Reporting Deadline Approaches or some time financial firms have been feeling the heat from ever more stringent regulatory pronouncements with regard to anti-money laundering (AML) and countering financial terrorism (CFT) requirements. For credit unions in particular, the date 31 March 2017 has particular significance in that regard as for the first time they will have to issue a statutory report on the measures they have adopted to counter money laundering and related areas.  But that deadline should not confuse credit union officers as to their responsibilities now. The 31st March 2017 is a reporting deadline (see below). In fact, credit unions are already required to have in place a comprehensive system of policies and procedures to counter money laundering and terrorist financing or officers risk severe punishment.  F Report on Anti-Money Laundering/Countering the Financing of Terrorism and Financial Sanctions Compliance in the Irish Credit Union Sector Page 1 Credit unions should be aware that they will be required to confirm annually that they have put in place appropriate measures to address the expectations outlined in the Report. This confirmation will be requested as part of the Anti-Money Laundering section of the 2016 Credit Union Annual Return due for submission to the Central Bank by 31 March 2017 and subsequent annual returns.
  4. 4. AML/CFT/FS – The Background inancial institutions worldwide have for years been grappling with escalating regulatory obligations in the area of Anti-Money Laundering (AML), Countering Financial Terrorism (CFT) and Financial Sanctions (FS). F The most infamous case to date of rank failure to observe international AML/CFT requirements is undoubtedly that of HSBC. In 2012 the world’s largest bank was fined a record USD1.92 billion by the US authorities for its role in aiding money laundering by various Mexican drug cartels. This came after HSBC Suisse was fined just over USD30 million by the Swiss authorities for “organizational deficiencies” that enabled its clients to launder cash. Money laundering is not a victimless crime. Criminality and associated money laundering “have a corrosive, corrupting effect on society and the economic system as a whole”, according to the IMF. To take one example, the effects of criminality and laundering can be readily gauged by the fact that some 25% of African states’ GDP is estimated to be lost to corruption each year. Page 2 A RBA to AML/CFT means that financial institutions8 are expected to identify, assess and understand the ML/TF risks to which they are exposed and take AML/CFT measures commensurate to those risks in order to mitigate them effectively. Source: FATF – Financial Action Task Force
  5. 5. Page 3 In tandem with international efforts, the Irish government and the Central Bank have ramped up legislation considerably in recent years. The Criminal Justice (Money Laundering and Terrorist Financing) Act of 2010 (CJA 2010) is the bedrock that brought the EU’s Third Money Laundering Directive into law. Next year these requirements will be extended by the implementation of the 4th EU Money Laundering Directive (MLD4). CJA 2010 sets out legal provisions to ensure technical compliance and effective implementation of international standards relating to AML and CFT. In the words of the Central Bank the Act: Defines broadly the offence of money laundering. Defines designated persons and beneficial owners that come under the provisions of the Act. Provides for Directions, Orders and Authorisations relating to investigations. Sets out customer due diligence, reporting, internal policies and procedures, training and record keeping requirements of designated persons. Provides for monitoring of designated persons. The leaked files mention hundreds of Irish companies and individuals who hold assets here or abroad by way of entities located in offshore jurisdictions Source: Colm Keena – Irish Times April 2016
  6. 6. More focus on senior management (the board of the credit union) responsibility for anti-money laundering (AML) and combating the financing of terrorism (CFT) controls, including personal liabilities. More focus on a risk based assessment of the credit unions AML/CFT threats and the management of those threats through adequate policy. More focus on the ongoing monitoring of members as part of “customer due diligence” (CDD) which goes beyond simply identifying members. Identification of the beneficial owner on all accounts and establishing if a member is acting on their own behalf, including identifying the beneficial owner in all school schemes, clubs and societies. Introduction of “enhanced due diligence” (EDD) or specific controls for higher risk circumstances. Introducing the notion of a “politically exposed person” (PEP) as a higher risk category of member. The requirement to identify members where doubts exist as to “the veracity of previously obtained documentation” – therefore the identification of all active members over time. The requirement to train all board members as well as relevant officers in the credit union. Page 4 More specifically, the new provisions of the CJA 2010 as they relate to AML/CFT include:
  7. 7. Introduction of a stricter and more enforceable standard for the reporting of suspicions. This is an objective test of suspicion – i.e. a definition of being “reckless” as to whether or not property represents the outcome of criminal conduct and requiring a report to be made if there are “reasonable grounds” for having a suspicion, i.e. would a reasonable person have been expected to make a report in the circumstances. Clear identification and extension of the Central Bank’s powers to effectively monitor and take measures, (including administrative sanctions) necessary to ensure compliance with the CJA 2010 which is specifically applied to credit unions. The Central Bank continues to be diligent in its AML/CFT actions and most recently issued its report on Anti-Money Laundering, Countering the Financing of Terrorism and Financial Sanctions Compliance in the Irish Funds Sector in November last year. Page 5 It is very important to note that the new provisions of MLD4 expand the definition of a PEP to cover domestic or resident PEPs. In other words Credit Unions are required to determine whether or not a member or beneficial owner connected with the member or service concerned is a PEP or an immediate family member or a close associate of a PEP.
  8. 8. Credit Unions and AML/CFT ecause membership of a credit union is restricted to those individuals who fulfil a specific qualification which is appropriate to the credit union (the “common bond”) there is an assumption that each credit union is on more intimate terms with its membership. The common bond is recognised by the Central Bank as “fundamental to the regulatory regime for credit unions.” B The Central Bank also recognises that a credit union offers primarily savings and loan products to its local or associational community, with limits on the level of savings an individual member can hold in the credit union, which are specified by the Central Bank. There are rules governing a credit union’s lending activity which are also specified by the Central Bank. In the words of the Central Bank, credit unions therefore presently operate within a restricted, often localised market, providing, at present, simpler financial services to members, not to the public at large. Typical credit union financial products and their community ethos do not deliver sufficient functionality or flexibility to be the first Page 6 choice for large scale money launderers and terrorist financiers. However, the Central Bank goes on to say, “this is not to say that credit unions have no risk of money laundering or terrorist financing.” In particular, the Bank notes the high level of cash transactions which are typical of credit unions.
  9. 9. In its Sectoral Guidance Note for Credit Unions on CJA 2010 the Central Bank identifies a number of higher risk activities that should alert credit union officers to the potential for money laundering and financing of terrorism. Money transfers to unknown third parties. Large one off transactions, particularly in cash. Third parties paying in cash on behalf of the member. Unusual loan or saving transactions such as larger loans made out to cash or to unexplained third parties. Large loans with unexplained short repayment schedules, or the acceleration of the agreed repayment schedule on larger loans (borrow clean, repay dirty). Reluctance to provide documentary evidence of identity when opening an account (even when taking into account financial exclusion issues). Page 7
  10. 10. Three Stages of Money Laundering The stages in the Money Laundering process are well recognized Placement is placing the proceeds of criminal activities in the financial system. Layering is the conversion of the proceeds of criminal conduct into another form and creating complex layers of financial transactions to disguise the audit trail and the source and ownership of funds. This stage may involve transactions such as loans or investments and very often may have an international dimension, i.e. conversion of currency or transfers abroad. Integration involves placing the laundered proceeds back in the economy to create the perception of legitimacy. This may involve purchase of high value goods or property Page 8 The Bank recommends Credit Unions exercise extra vigilance in the following situations: The excessive presentation of third party cheques or drafts by members. Members taking out larger loans – where funds would seem more readily available and the transaction seems economically unviable. Services provided to cash generating businesses, including due care when accepting cash from local businesses, that it represents the true turnover of the business. Accounts open with unusual versions of name, or bogus or false names, or requests for multiple accounts for a single member. Use of, or requests for, large amounts of high denomination notes (€200 & €500). Significant unexplained foreign exchange activity. Significant activity in children’s accounts where it would seem unreasonable that the child was the beneficiary, (i.e. parents using children’s accounts for significant transactions).
  11. 11. Credit Unions and AML Compliance – Where we are now In May 2015 the Central Bank issued its Report on Anti-Money Laundering/Countering the Financing of Terrorism and Financial Sanctions Compliance in the Irish Credit Union Sector. The Report was the outcome of a series of on-site inspections carried out by the Central Bank and supplemented by Risk Evaluation Questionnaires submitted to the Central Bank for evaluation. Its findings were overwhelmingly negative. “The number and nature of issues identified during the inspections of the credit union sector suggest that credit unions in Ireland need to significantly improve their AML/CFT policies, procedures, systems and controls to ensure compliance with the CJA 2010,” the Bank reported. Failure to implement the requirements of the CJA 2010 in a timely manner. Lack of oversight of AML/CFT issues at Board level; Inadequate policies, procedures and processes in relation to Customer Due Diligence (CDD) for new and existing members, on-going monitoring and classification of risk; Engaging in non-standard practices without appropriate Board oversight and approval and without proper policies, procedures and systems and controls in place. For example, accepting large cash lodgments from local businesses, or lodgment of business proceeds to members’ personal accounts, without considering and documenting any risks associated with these practices or any additional due diligence or on-going monitoring requirements which may apply; Lack of documented procedures to identify and verify beneficial owners where warranted, for example in the case of business customers, clubs and societies etc.; Among the issues identified by the Bank were: Page 9
  12. 12. Non-adherence to stated AML/CFT policies; Failure to conduct adequate Money Laundering/Terrorist Financing risk assessment of the business; Failure to have adequate systems and controls, procedures and documentary evidence of on-going monitoring of transactions; Failure to define Politically Exposed Persons (PEPs) within policies. Lack of systems and formal processes for identifying, verifying and monitoring PEPs; Failure to ensure the provision of appropriate training to the Board members, staff and volunteers at all levels, as well as enhanced training for staff in key AML/CFT and FS roles; Inconsistent and/or undocumented approaches for the reporting of Suspicious Transaction Reporting (STR) by staff to the Money Laundering Reporting Officer (“MLRO”), or the process for onward reporting to the relevant authorities. Lack of a documented timeframe for reports to be received and reported and failure to reference the penalties for not reporting or the offence of ‘tipping-off’ within the AML Policies. Page 10 It is very important to note that the new provisions of MLD4 expand the definition of a PEP to cover domestic or resident PEPs. In other words Credit Unions are required to determine whether or not a member or beneficial owner connected with the member or service concerned is a PEP or an immediate family member or a close associate of a PEP.
  13. 13. Risk-Based Approach Under CJA 2010 credit unions are required to apply a risk-based approach to AML that ensures that its strategies “are focused on deterring, detecting and disclosing risks of money laundering or terrorist financing in the areas of greatest perceived vulnerability.” The steps it takes should be documented in a formal policy statement “which assesses the most effectual and proportionate way to manage these money laundering and terrorist financing risks.” These steps must include: Identifying the money laundering and terrorist financing risks that are relevant to the credit union. Assessing the risks presented by the credit union’s particular: Members Products Delivery channels Geographical areas of operation. Identification and categorisation of higher risk members. (S. 37 & S.39) Designing and implementing controls to manage and mitigate these assessed risks. Monitoring transactions, including the large, complex or unusual. (S. 54(3)) Recording appropriately what has been done and why. Page 11
  14. 14. Money Laundering/Terrorist Financing Risk Assessment Page 12 Member Standard Lower Risk Medium Risk High Risk Well known established members Adequately identified new members Non domestic PEPs. Members of Sanctions List (these accounts must be frozen!) (These accounts likely to be rare in credit unions but must be checked) Less well known members. Possible gaps in identification. i.e. out of date address information. Pre 1995 members. Domestic PEPs where known.Cash intensive businesses; i.e. pubs, service stations, gambling firms, dealers in high value goods (car dealers, jewel, art & antique dealers) Product or Service Simple low value savings and loan products General Insurances More complex very high value type products/services, i.e. wealth management, correspondent banking, complex trust or company structures. (These products not currently offered by credit unions) Larger transactions, larger share balances and loans. More complex products/ services; ultimate beneficiary may not always be clear. Foreign dimension; use of payment service provider, i.e. Western Union or provision of substantial foreign exchange Delivery Channel Direct to member Members not identified face to face Internet only business (Not currently offered by credit unions) Not always face to face; use of telephone and Internet. Payments to 3rd parties, i.e. loan cheques made out to 3rd parties, or receipts by one member into multiple 3rd party accounts. Geography Not close to Border/Port No Foreign Exchange Funds to or from high risk jurisdictions: see FATF list of jurisdictions (Rare in most credit unions) Foreign exchange or alternative remittance system used extensively. Areas that are known to have high levels of criminality or terrorist activity Actions Required From credit Union Standard Identification; OK to use exceptional cases ID, i.e. in cases of financial exclusion Minimal ongoing monitoring required Enhanced Due Diligence Required; Identify source of wealth or funds along with Standard Identification. Detailed ongoing monitoring required Sign-off from Board may be required before relationship is permitted. Standard identification; but take care if relying on exceptional cases ID alone. Ongoing regular monitoring required; i.e. reports of transactions/balances lodged over certain thresholds Source: ILCU The above is a sample suggested Red/Amber/Green money laundering/terrorist financing risk analysis for credit unions. It should allow credit unions to identify which circumstances might contain standard, medium or higher risks of money laundering and terrorist financing. Under a risk-based approach, a credit union should focus resources on tackling its identified higher risks (red lights). Also credit unions are reminded that as circumstances change so might their AML/CFT risks. As well as ongoing monitoring, a formal analysis of AML/CFT risks should be undertaken on an annual basis, perhaps as part of the AML Compliance Officer’s/MLRO’s annual report to the board. This form must be adapted to the credit unions particular circumstances.
  15. 15. Senior Management Responsibility and Internal Controls Page 13 The board in conjunction with management must ensure suitable controls are designed and implemented which must include: The credit union’s AML/CFT policy should be reviewed on at least an annual basis. In addition “qualified parties who are independent of the implementation of the credit unions AML compliance programme (such as internal audit, external audit or external professionals) may be engaged to review AML/CFT policy and procedures to ensure they are set-up and operating effectively.” Credit unions should allocate to an officer (likely to be the new Compliance Officer - who may or may not also be the money laundering reporting officer, MLRO) overall authority within the credit union for the establishment and maintenance of effective anti-money laundering systems and controls. One of the key tasks of this individual should be the drawing up of an annual report to the Board on the operation of the credit union’s AML/CFT systems and procedures providing a reasoned assessment of the credit union’s compliance with AML/CFT legislation and guidance. A formal AML/CFT risk assessment. Customer Due Diligence measures including adequate identification of all members and identification of beneficial owners and Politically Exposed Persons (PEPs). On-going member monitoring procedures including identification of complex or large transactions and unusual patterns of transactions that have no apparent economic or visible lawful purpose. Reporting of all suspicions. Training of all relevant officers, including all directors. Record keeping. Policies and procedures for the monitoring and management of compliance with the Internal communication of the policies and procedures above.
  16. 16. Customer Due Diligence (CDD) Page 14 The CJA 2010 requires that CDD be applied to existing customers where there exist: “reasonable grounds to doubt the veracity or adequacy of documents or information previously obtained for the purposes of verifying the identity of the customer.” This Central Bank acknowledges that this obligation presents “significant practical problems for credit unions” particularly in obtaining and verifying new identification information in relation to existing members. The Bank specifies those members who may have joined before the implementation of the original Criminal Justice Act, 1994 and were therefore exempted at the time from obtaining and verifying identity. Nonetheless, the Bank recommends that a credit union reviews appropriate identification data held for an existing member in the following trigger circumstances: The credit union’s risk-based assessment of its business indicates that the member in question falls into a higher than standard risk category, such as when moving to a higher risk product or service. A member looks for a new product or service, i.e. a new loan application, or moves to a new type of account. The member’s account has been previously inactive for a certain period of time where this is unusual for the nature of the service being provided. A transaction of significance takes place, such as a large lodgment or withdrawal. Doubt has arisen in the normal course of business in relation to previously obtained documentation or information. Doubt has arisen in the normal course of business that the member, contrary to previous information, is acting on their own behalf. The credit union has any suspicion that the member may be involved in money laundering or terrorist financing.
  17. 17. Page 15 Inevitably, most of the focus on CDD falls with new members. And this is even more focused in the case of Politically Exposed Persons (PEPs) who must be subjected to enhanced Due Diligence procedures. At present, a PEP is understood to be a foreign national who has in the previous year held a prominent public function. But MLD4 is set to extend the requirements around PEPs significantly. MLD4 clarifies the definition of a politically exposed person (PEP) and widens the categories of individuals who can be regarded as PEPs to include members of the governing bodies of political parties, and directors, deputy directors and members of the board or equivalent function of an international organisation. Most importantly, the rules relating to PEPs are also extended to cover domestic PEPs. MLD4 requires that, when a person ceases to be a PEP, an Obliged Entity must consider the continuing risk imposed by that person for at least twelve months. Risk-sensitive measures must be applied until that person is deemed to pose no further risk specific to PEPs. Furthermore, Obliged Entities are not entitled to rely exclusively on PEP lists, they are responsible for making their own determination as to whether a customer is a PEP, or associated with a PEP. The RBA is not a “zero failure” approach; there may be occasions where an institution has taken all reasonable measures to identify and mitigate AML/CFT risks, but it is still used for ML or TF purposes. Source: FATF – Financial Action Task Force
  18. 18. According to Central Bank guidelines, all staff and volunteers need to know the credit union’s internal reporting process, so that they know how to report suspicious activity. In credit unions, reports will be made directly to the MLRO. Credit unions are urged to consider a reporting template in which to standardise and simplify the internal reporting process. Reporting The Central Bank deems the role of the MLRO as central to the credit union’s AML/CFT reporting process. The credit union must appoint an officer as MLRO whose legal responsibility it is to receive and act upon suspicion reports. Page 16 The guidelines issue the folowing checklist to determine the merit of making a report: Does the transaction make sense in the context of the member’s business or personal activities? Is the size of the transaction expected or usual? Is the transaction out of proportion to the normal expected income and expenditure of that member? Has there been a recent significant change in the pattern of transactions? Is the total value of a series of transactions substantial? Is the pattern of repayments on a loan consistent with the member’s earnings? Are there many transfers to high-risk jurisdictions without reasonable explanation? Reporting
  19. 19. Page 16 To make sure you can stand over your statutory AML/CFT report by 31 March 2017, Stubbs Gazette has marshalled its resources to provide the credit union movement with a systematic, integrated suite of tools and media. Remember, this is not for some future AML/CFT requirement, this is for current AML/CFT regulatory requirements. This comprises our Enhanced Customer Due Diligence system (ECDD), four staggered workshops to cover all of your requirements, in-house and external training and a certified exam prior to D-Day Workshop 1 – comprises a review of the Central Bank report. Workshop 2 – the 3 Ps – Policies, Procedures, Processes. Workshop 3 – Reporting suspicious transactions and the role of the MLRO. Workshop 4 – Preparing for an AML/CFT Audit. How StubbsGazette Can Help 2016 2017 Today Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2017 Workshop 1 - Review Central Bank Report 3/31/2016 Workshop 2 - The 3 P's - Policies, Procedures, Processes 6/16/2016 Workshop 3 - Reporting STRs, Role of MLRO 9/15/2016 Workshop 4 - Preparing an AML/CFT Audit 11/17/2016 3 day course & Exam 12/1/2016 Switch on ECDD - Enhanced Customer Due Diligence System2/1/2016 - 4/14/2016 3/10/2016 - 4/30/2016 4/15/2016 - 6/1/2016 6/16/2016 - 7/7/2016 Batch match all members - existing and dormant Classify High Risk Members Switch on monitoring and alerting for HRMs In house training for all staff Online interactive classes5/1/2016 - 12/15/2016 In house training for all staff Daily Monitoring of PEP/Sanction Lists Credit Union AML/CFT/FS Compliance A Risk Based Approach 4/15/2016 - 6/23/2016 12/16/2016 - 1/11/2017 Page 17
  20. 20. Page 18 The Central Bank findings give an indication of the challenges faced by Credit Unions in satisfying the AML/CFT requirements of the Central Bank. StubbsGazette is pleased to have for some time been a key source for financial institutions intent on verifying their clients’ bona fides and legitimacy and now we have massively expanded the scope of our search facilities to assist financial institutions in meeting their regulatory obligations in AML/CFT, Due Diligence – what you need to know Under the provisions of The Criminal Justice (Money Laundering and Terrorist Financing) Act of 2010, ‘designated persons’ within Credit Unions are responsible for customer due diligence, reporting, internal policies and procedures, training and record keeping requirements. StubbsGazette‘s Enhanced Customer Due Diligence service at a stroke removes the most onerous aspect of the new obligations. This online service gives credit union officers the ability to verify in real-time the existence or otherwise of the following categories of individuals within the credit union customer base: Persons of Special Interest (SI): Individuals assigned Special Interest status due to their involvement in selected criminal activities such as fraud, money laundering, trafficking, terrorism, corruption or organized crime. Politically Exposed Persons (PEPs): A person who is, or has at any time in the preceding 12 months been, been entrusted with a prominent public function. Relative or Close Associate (RCA): The PEP definition is extended to include family members and known close associates of a PEP. Likewise for RCAs of Special Interest persons. Sanctions Lists (SAN), Other Official Lists (OOL), Other Exclusion Lists (OEL) Risk & Compliance profiles contain the names of individuals, companies, organisations, aircraft, banks and vessels contained in over 900 current international official lists covering 60 jurisdictions. Lists published by the U.S. Office of Foreign Assets Control (OFAC), the United Nations and the European Union are included.
  21. 21. Page 19 StubbsGazette will be making available to its subscribers a comprehensive database specifically designed towards providing background checks to identify potentially compromised individuals for the purposes of anti-money laundering and countering the financing of terrorism. Specifically, the following categories will be highlighted. Heads & Deputies State/National Government Presidents,Taoiseach etc. National Government Ministers This category contains a country’s government ministers, for example, Minister of Finance, Minister of Foreign Affairs etc. Members of the Dail, Seanad, Stormont Assemby etc This category contains members of the bodies/assemblies making up the national legislature Senior Civil Servants–National Government This category contains the uppermost levels of the regional civil service. Titles vary depending on the country concerned, but include those like Secretary General etc. Embassy and Consular Staff, the top two positions at a country’s foreign representations and the top position at a country’s consulates.. Senior Members of the Defence Forces. Senior Members of the Police Services (Garda Siochana, PSNI). Senior Members of the Secret Services Senior Members of the Judiciary State Corporation Executives, State Agency Officials, Heads & Deputy Heads of Local Government, Religious Leaders, Political Party Officials. International Organisation Officials City / Town Mayors,Political Pressure and Trade Union Officials International NGO Officials, Local Public Officials, Local Councillors etc. International Sporting Organisation Officials Relatives or Close Associates (RCA) Special Interest Persons (SIPS) – individuals involved in selected criminal activities such as fraud, money laundering, trafficking (of people, drugs weapons and/or other items), terrorism or supporting terrorism, corruption and/or organized crime A Politically Exposed Person can also be catagorised as a SIP if such a person is involved in one or more of the above activities.
  22. 22. Page 20 ‘Batch match’ your existing customer base Provide real-time verification and validation at customer onboarding stage Deliver ongoing monitoring and reporting, particularly of higher risk customers StubbsGazette ECDD service will give you the comfort you need to ensure you satisfy all aspects of the Central Bank’s customer due diligence requirements with immediate practical effect. The service will immediately: ECDD is just the beginning of a suite of new services designed to equip Credit Unions with the tools they need for the new AML/CFT regime. Beginning in April 2016, StubbsGazette will host a series of workshops and to ensure subscribers will have in place robust policies and procedures to satisfy Central Bank requirements before the March 31 2017 deadline date. In addition, StubbsGazette will put in place a robust credit union AML training regime to allow credit unions satisfy Central Bank requirements. It is an offence not to train credit union personnel in their AML/CFT obligations. A successful defence by a staff member or volunteer of not having been trained could make the credit union itself guilty of the money laundering offence. Penalty on conviction for not training is a fine or imprisonment for a term not exceeding five years, or both. Central Bank Guidance Note for Credit Unions, CJA 2010
  23. 23. Page 21 AML Anti-Money Laundering CDD Customer Due Diligence CFT Countering the financing of terrorism CJA 2010 The Criminal Justice (money Laundering and Terrorist Financing) Act 2010 DPC Data Protection Commissioner ECDD Enhanced Customer Due Diligence FS Financial Sanctions ID&V Identify & Verify IFB Irish Fraud Bureau MLD4 The 4th Money Laudering Directive MLRO Money Laundering Reporting Officer OOL Other Official List PEP Politically Exposed Person RBA Risk Based Approach RCA Relative & Close Associate SCD Simplified Customer Due Diligence SI Special Interest Person SI-LT Special Interest Person (Lower Threshold) SOF Source of Funds STR Suspicious Transaction Report TF Terrorist Financing GBFI Garda Bureau of Fraud Investigations Appendix Glossary
  24. 24. If you have any further questions please do not hesitate to contact us on +353 1 6725939 or email