AML training must be more than mere lip service

AML training must be more than mere lip service

In a recent sanction by the Central Bank, attention is being drawn to the fact that anti-money laundering (AML) training needs to be focused, specific and ongoing. In the sanction report, a financial services firm was fined €443,000 in June 2018 for failures that included lack of appropriate AML training.

The sanctions report reads: ‘it had inadequate policies and procedures to monitor transactions, detect and report money laundering and provide its staff with appropriate training’.

In addition, the Central Bank found that the company:

  • failed in many areas to provide the appropriate amount, level, and accuracy of training for its staff;
  • training was not focused on the specific roles and responsibilities of staff (especially at Money Laundering Reporting Officer (MLRO) level;
  • training did not amount to a sufficient amount of time to train them on how to identify suspicious activity;
  • the entity failed to provide training to all client facing staff; and
  • there was a failure to ensure staff were instructed on AML and counter financing of terrorism (CFT)-related law, and a failure to provide ongoing training.

From 15 July 2010 to 10 September 2012, the firm breached section 54(6) of the Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010, because it failed to train anyone involved in the conduct of its business in AML/CFT law or provide on-going instruction on identifying suspicious activity.

Over a three-year period, the firm had held one-hour annual AML/CFT training session for staff. The Central Bank stated the ‘training was sufficient to introduce staff to AML/CFT law but in further breach of section 54(6), it was insufficient to train them to identify suspicious activity. In addition, the scope of the training was not tailored to specific roles, including the Firm’s MLRO’.

To hear more about the AML requirements that must be applied by accounting firms, including a suggested spreadsheet to control all the main topics, come to our next AML seminar on Tuesday 25 September 2018 at the Talbot Hotel Stillorgan, County Dublin.

Booking is here via our website. Cost is €105 per delegate or €280 for three delegates from the same office.

Insurance Brokers must now file fully unabridged financial statements with CRO

Insurance Brokers must now file fully unabridged financial statements with CRO


Since the implementation of the new Companies Act, 2014 on 1 June 2015, the financial statements of regulated insurance intermediaries and investment brokers will no longer qualify for certain exemptions.

Those affected are those carrying on business under the Insurance Act, 1989 or otherwise authorised by the Central Bank. The full list of entities affected is on the 5th Schedule of the Companies Act, 2014

This applies to financial statements approved by the directors on/after 1 June 2015 and means they:

1. Are not allowed to qualify for the ‘small’ or ‘medium’ thresholds as defined in company law;

2. Cannot abridge their financial statements. They must file full accounts with the CRO;

3. Cannot avail of audit exemption;

4. Cannot avail of the FRSSE (the Financial Reporting Standard for Smaller Entities (January 2015);

5. Must apply FRS 102 in full with effect from financial years commencing on/after 1 January 2015 (including a compulsory cash flow statement);

6. Must disclose auditor remuneration in the four categories required by section 322 of the Companies Act, 2014 (along with comparatives);

7. Cannot use FRS 105, the proposed micro-entities standard, when it is endorsed in Irish company law (expected to be signed off later this year);

8. Will not be allowed adopt section 1A of FRS 102 even after it has been endorsed in Irish company law (expected to be signed off later this year for certain other entities).

9. Will not be allowed use the PASE (Provisions Available for Smaller Entities) as the entity is deemed to be large.

To hear more about financial reporting developments in FRS 102 and in FRS 102 for Charities (and other Not for Profit Entities) including the Charities SORP please come to our upcoming training days in Dublin and Cork. See our CPD courses page for the latest news.