The fine was 2,275,000 EUR for the following AML failures – AIB failed to:
- Report suspicious transactions without delay to An Garda Síochána and the Revenue Commissioners.
- Conduct customer due diligence (‘CDD’) on existing customers who had accounts prior to May 1995 (‘Pre–95 customers’) when the first Irish laws on anti-money laundering and countering the financing of terrorism (‘AML/CFT’) became effective.
- The Central Bank also identified breaches in respect of AIB’s AML/CFT policies and procedures in a number of areas, including the above, and its trade finance business.
And these are the factors that the central bank used in setting the penalty:
- Seriousness with which the conduct is viewed, particularly given AIB’s central role in the financial services system and the high risk nature of retail banking business in terms of ML/TF.
- The extended period of time over which the breaches occurred, spanning the period from 15 July 2010 to 8 July 2014.
- The co-operation of AIB during the investigation and in settling at an early stage in the Central Bank’s Administrative Sanctions Procedure.
- The actions taken by AIB to remediate the breaches.