John McCarthy is a regular speaker on data protection, GDPR, Compliance, and Anti-Money Laundering (AML)
He has published a guide to the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018, which became law on 26 November 2018.
Here is the link to the John McCarthy Consulting Ltd – Publications Store
The main changes introduced by the 2018 Act is that it introduces the requirement to:
- Carry out a Business Risk Assessment of the business/firm itself;
- Identify locally based Politically Exposed Persons (PEPs) and treat them (as well as certain connected family members) as high risk;
- Enhance the existing requirements for carrying out customer due diligence, maintenance of more detailed training records);
- For those businesses that deal in goods sold for cash, the threshold when AML identification of the customer is required, now starts at €10,000 (rather than €15,000 heretofore);
Launch the central register of beneficial owners to be maintained in each EU country. In Ireland, this will be kept at the CRO. This register will be formally launched in 2019. See more in Appendix
AML Policies controls & Procedures Manual (June 2019) (73 pages) – This contains everything you need to successfully implement the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which became law on 26 November 2018 an the Register of Beneficial Ownership which is coming into effect later in 2019.
Comes with a free of charge Excel spreadsheet called the ‘AML Control Sheet’ which firms may use to give a ‘helicopter’ view of progress made with keeping client AML data up to date.
It includes eleven Appendices with templates/guidance on how to implement the legislation efficiently.
The Chapter headings in this manual are:
- AML Procedures
- The Business Risk Assessment
- Simplified Due Diligence (SDD)
- Standard/Normal Due Diligence (NDD)
- Enhanced Due Diligence (EDD)
- Third Party Reliance
- Relevant Third-Party Arrangements
- Reporting Requirements
- Exemption from Reporting
- External Reporting
- Tipping Off
- Record Keeping
- AML Compliance Review
- Penalties & Fines