The Irish government has announced a bid to host the EU centralised Anti-Money Laundering Authority (AMLA) in Dublin. A successful bid would create around 600 new Irish jobs, although there may be some displacement of the Central Bank of Ireland (CBI) staff for areas of supervision ceded to AMLA.
Dublin’s International Financial Services Centre, set up over 30 years ago, has become one of the leading hedge fund service centres in Europe, as well as a hub for major aircraft leasing, insurance and global banking organisations. It has created thousands of financial services jobs, and using this as an example it is easy to envisage additional employment arising directly and indirectly from a successful AMLA bid.
In addition to any direct employment, a common EU rule book and a regulator located in Ireland will serve to attract the shared centralised AML compliance function of the big international banks to Ireland. This will create additional indirect employment. Some of these banks already have their EU or worldwide centralised AML function in Dublin, and one mid-tier accounting firm in Dublin has 120 staff providing AML consulting services to clients.
AMLA would be located in one city but will regulate all the large banks in every member state
The EU has learned from weaknesses in the distributed nature of the regulation of GDPR, where every member state regulated entities in their own country only. As a result, one small member state ended up being responsible for supervising most of the big social media companies because they were headquartered here. AMLA would be located in one city but will regulate all the large banks in every member state.
Centre of excellence
A recent salary survey showed that AML/CFT compliance specialists in financial services are on an average salary of €97,670. Five years ago, ACCA began a project to build a centre of excellence for AML in Ireland.
Accountants working in practice are designated persons under the anti-money laundering regulations
For members keen to upskill to avail of the new opportunities, training in AML, ranging from short CPD type courses to Level 9 diplomas – many supported by Springboard or Skillnet funding – is available from providers who include:
Reporting obligations
Accountants working in practice are designated persons under the anti-money laundering regulations. This means that they must have policies and procedures in place to allow them detect suspicions of anti-money laundering and to report those suspicions to the relevant authorities.
Potentially multiple reports must be made to different authorities about the same incident
But accountants also have a reporting obligation under Section 1079, Taxes Consolidation Act 1997; Section 59, Criminal Justice (Theft and Fraud Offences) Act 2001; Section 19, Criminal Justice Act 2011; Section 393, Companies Act 2014; Section 59, of the Charity Act 2009 and under certain circumstances a Statutory Duty report to the Central Bank and a duty to report to Companies Registration Office. Each obligation has a different reporting threshold, different time limits, tipping off restrictions or encouragement to discuss the matter with the client and a different authority to report to.
The red flag training guide is a resource to assist practices in determining who to report to and what to report in all the various circumstances. The guide identifies typical situations that an accountant in practice might come across and how to respond in terms of further investigation and the potentially multiple reports to be made to different authorities about the same incident.
Sanction testing
During their AML monitoring visit, practitioners will be asked how they sanction test their clients. While third-party applications will automate this for a fee, it can be carried out manually.
A person with connections to a country in conflict is checked annually
Search online for ‘sanction list EU’ or go directly to this link. The list is around 1,000 pages long but it can be downloaded in pdf format. Search by typing in the name of a client and/or business to see if they are sanctioned.
The search needs to be done initially on accepting a new client and thereafter rechecked on a risk-based basis. A person with connections to a country in conflict should be rechecked annually but a client who is well known to the practice and has a very low-risk profile for AML/CFT will only need to be checked once.
More information
ACCA’s annual virtual conference, ‘Accounting for the Future’ features a session on fraud risk. Register today to watch live on 21-23 November or on-demand.
