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Since 2011 the anti-money laundering/counter terrorist financing (AML/CTF) supervision unit of the Central Bank of Ireland (Central Bank) has been conducting inspections on the investor documentation of both UCITS and Non-UCITS investment funds under the provisions of the Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010 (CJA 2010). The scope of the investment fund inspections has included a detailed review of the:

  • customer due diligence (CDD) procedures used to identify and verify investors;
  • nature and duration of non AML compliant investors;
  • nature and level of AML/CTF training provided to those persons involved in the conduct of the investment fund;
  • arrangements with any third party on which the investment fund is relying for AML/CTF purposes.

The Central Bank inspections have placed increased focus on the requirement for boards of directors to:

  • familiarise themselves with the obligations under the CJA 2010 and undergo appropriate AML/CTF training in accordance with Irish law;
  • demonstrate how the investment fund is in compliance with the CJA 2010 where there is insufficient CDD documentation on file for investors;
  • understand the AML/CTF procedures of the relevant fund administrator to ensure the investment fund meets the requirements under the CJA 2010.

For further information in relation to the above please contact Money Laundering Reporting Officer (MLRO)

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