On 07 February 2013, the Department of Finance published an Anti-Money Laundering Sectoral Guidance Note for the Credit Union Sector (“Guidance”). The Guidance was drafted by the ILCU and aims to assist credit unions in complying with their obligations under the CJA 2010.
The Guidance provides information and clarity in respect of the following areas:
- Scope of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010
- Money Laundering & Terrorist Financing Risks in Credit Unions
- Assessment and Management of a Risk-based Approach
- Senior Management Responsibility
- Customer Due Diligence
- Internal Controls, Polices and Procedures
- On-going Monitoring
- Reporting – MLRO and AML Officer
The Guidance Note is not intended to be exhaustive and credit unions must always refer directly to the Act to determine their statutory obligations. Credit unions should be aware however that the Central Bank will have regard to these guidelines in any examination by it of a credit union’s compliance with the CJA 2010. The Core Guidelines published by the Department of Finance (latest edition February 2012) should also be referred to.