CCAB-I has revised and updated its anti-money laundering guidance for accountants (“Guidance”) and the update has recently been released to members. The update is the result of some months of work by a working party made up of a cross section of individuals including from the professional bodies, practice and industry.
The review was carried out mainly to update the Guidance to take account of changes brought about in recent years by the fourth and fifth EU anti money laundering directives. Those directives were brought into Irish law by a series of regulations (statutory instruments) and the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021.
Updates include a re-vamp of the section on beneficial ownership. An entire section of the Guidance is now devoted to beneficial ownership. It includes information on obligations on companies and other legal entities and trusts to establish internal beneficial registers and to register certain information on central registers.
Some updated guidance is provided on reporting procedures and additions have been made in relation to customer due diligence (CDD) to reflect recent changes in the areas of complex business structures, high risk third countries and PEPs.
In the “Suspicious Transaction Reporting” section there are links to FIU Ireland guidance “
Reporting Entity Registration Guide” and “
GoAML WEB Reporting Quick Reference Guide” which are guides for designated persons on how to register and report on GoAML and also FAQs and guidance from FIU Ireland on how to find and amend a Rejected STR
.
Firms are advised to review the changes made to the guidance and to update their policies and procedures accordingly. For details, please click
here.