As the Deputy will be aware, the relevant international standard setting body for Anti-Money Laundering is the Financial Action Task Force (FATF). It has not raised such concerns with my Department in the period since 2021.
My Department received correspondence in January 2022 regarding Ireland’s practical application of the Fourth Anti-Money Laundering Directive (2015/849), arising from the European Commission’s assessment conducted in 2020-21. This included questions on the following areas: Risk Assessment, Customer Due Diligence (CDD), Financial Intelligence Unit (FIU), Suspicious Transaction Reporting (STR), Supervision, Cooperation and Beneficial Ownership.
Ireland’s official response in September 2022 outlined work underway at that time by AML/CFT supervisors, the FIU and the registers of beneficial ownership information to drive improvements in a number of these areas. Specifically, in relation to customer due diligence/ know-your-customer controls, reference was made to the amendments to the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 which were made in 2021. Section 35 of this Act includes strengthened CDD rules by adding an obligation to conduct checks on beneficial ownership before business relationships are formed, while Section 36A introduced closer scrutiny of unusual or high-risk transactions. Furthermore, Section 38A requires additional information to be obtained when dealing with customers from high-risk jurisdictions.
Further work to strengthen Ireland’s framework for combating money laundering and terrorist financing is currently underway via transposition of the 6th Anti-Money Laundering Directive.