On 1 February 2013 the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill 2013 was published. The draft Heads of this new Bill were first published in June 2012. The primary purpose of the Bill is to amend the CJA 2010 in order to align certain provisions more closely with international standards and to amend some provisions to reflect operational requirements. The proposed changes include amendments to customer due diligence (“CDD”) requirements in respect of the politically exposed persons and high risk customers and changes in respect of the content of a firm’s AML and CFT policies and procedures.

Conclusion

Anti-Money Laundering remains firmly on the Central Bank’s priority list for 2013. In its recently published Enforcement Priorities and Programme of Themed Reviews and Inspections, it stated that a programme of desktop inspections and a number of on-site inspections will be conducted throughout the year. It further stated that where serious breaches occur, regulated entities, and the personnel deemed responsible for the breaches, can expect vigorous investigation together with significant fines and sanctions. Credit unions should therefore ensure that they remain fully aware of their obligations under the CJA 2010.