AML/CMT Framework Consulting
The EU’s framework on anti-money laundering (AML) and countering the financing of terrorism (CFT) has evolved in line with the work and recommendations of the Financial Action Task Force (FATF), the main international body responsible for combating money laundering (ML), terrorist financing (TF) and other threats to the integrity of the international financial system. Starting in 1991, the EU has adopted and revised its AML framework on the basis of the 1st AML directive with the current regime resting on the 6th AML Directive.
At the national level, compliance with the AML framework involves national competent authorities within member states who supervise the AML/CFT regime and examine obliged entities for adherence to the country’s AML regime (national legislation and regulation). National competent authorities (Central Bank of Ireland) have the ability to impose fines for non-compliance.
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Credit Unions and AML/CFT
‘Designated persons’ under the Criminal Justice Act 2010, including all credit and financial institutions are required to comply with their obligations under the CJA 2010.
The CJA 2010:
defines broadly the offence of money laundering;
requires designated persons to identify non-domestic politically exposed persons (PEPs);
requires identification of the beneficial owners of legal entities, such as companies and trusts;
requires designated persons to focus on the level of risk of money laundering and terrorist financing in meeting their obligations under the CJA 2010; and
requires the Central Bank to effectively monitor credit and financial institutions (as defined in the CJA 2010) with regard to their obligations under the CJA 2010, and to take measures that are reasonably necessary to secure their compliance.
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Where to start developing AML/CFT Framework?
The Central Bank published in May 2015 ‘Report on Anti-money laundering (AML), Countering the Financing of Terrorism (CFT)) and Financial Sanctions (FS) Compliance on the Irish Credit Union Sector’. The report was compiled using a combination of both on-site and off-site elements and focused on;
AML/CFT compliance governance and controls;
Customer Due Diligence (“CDD”);
On-going Monitoring;
Suspicious Transaction Reporting (“STR”);
EU Financial Sanctions;
Risk Evaluation Questionnaires (“REQs”) completed by CUs
The construct of the report and issues raised can be the starting point for a “Gap Analysis” exercise through which a credit union can recognise its current AML/CFT framework against the criteria called out within the report
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How can we help?
AML/CFT services to its Credit Union clients include:
AML/CFT gap analysis reporting;
AML/CFT Business Risk Assessments;
Policy and procedures;
Money Laundering Compliance (MLCO) Programmes
Training
Would you like to discuss AML/CFT?
Don't hesitate to get in touch with our team
Frequently Asked Questions
What is Operations Resilience
The ability of a firm, and the financial services sector as a whole, to identify and prepare for, respond and adapt to, recover and learn from an operational disruption.
In times of uncertainty, effective leaders keep their organisations running, with high levels of service availability and sufficiently robust frameworks that ensure that the interests of members are safeguarded during any business disruption.
What does a typical Operations Resilience Project look like?
We work closely with your Board of Directors, Management Team and Employees to get buy-in at all levels.
The Strategic Framework is agreed at the start with BoD and management team through workshops.
The project execution entails individually tackling all areas listed in the Three Pillar Approach listed in the Central Bank's guidelines.
This includes, but is not limited to SolutionOut's project team working with your team and completing the major deliverables below:
Identifying critical processes and associated tolerances
Process Mapping and documenting the critical processes
Mapping third party dependancies
Conducting Process analysis, documenting and testing mitigation plans
Reviewing and updating BCP, Cyber Resilience, Incident management, Communication and Learning Strategies
These are done through workshops and individual consultations with process experts in your business.
Documentation is created and signed off with the relevant stakeholders.
Training and support are provided to make the team self sufficient to update and manage the deliverables in the future.
How much does this project cost?
Operations Resilience is an investment for the future. There are different approaches to pricing that can help make it suitable for you. Please contact us and we can discuss what works best for you.