I can inform the Deputy that, since 2010, there has been one fine imposed on my Department by the Court of Justice of the European Union (CJEU). This was in relation to a delay in transposing Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. On July 16, 2020, the CJEU imposed a €2 million lump-sum fine for this delay.
The delay referred to a period between 2017 and 2019 relating to the enactment of primary and secondary legislation including the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 and regulations in respect of beneficial ownership.
This delay mainly arose due to the complexity of the changes that were required under the Directive. It required detailed amendment to the 2010 Money Laundering Act. The analysis and settling of those amendments took a significant length of time and required extensive work on behalf of the Office of Parliamentary Counsel, the Office of the Attorney General and the Departments involved
The Court accepted that the Directive has now been fully transposed, and no further fines will arise in respect of this matter.