This Report details the CBI's observations in respect of compliance with AML/CFT and FS requirements by banks in Ireland. It is hoped that financial and credit institutions in Ireland will take into account the observations and expectations dealt with in this Report in order to assist firms in enhancing and developing their AML/CFT and FS procedures. Some of the key failures identified in the Report include:
- Incomplete risk assessments;
- Inadequate training to all staff members and a failure to provide comprehensive training to Board members; and
- Non-adherence to certain AML/CFT and FS policies (for example internal policies not being subject to regular review or not being reviewed in accordance with the bank's own stated review cycle).