On 8 May 2019, the Central Bank of Ireland (the “Central Bank”) reprimanded and imposed a fine of €280,000 on Campbell O’Connor & Company (the “Firm”) for five breaches of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the “CJA 2010”). The Firm has admitted the breaches.
The Central Bank determined that the appropriate fine was €400,000, which was reduced by 30% to €280,000 in accordance with the settlement discount scheme provided for in the Central Bank’s Administrative Sanctions Procedure.
The Central Bank’s investigation into the Firm commenced following a themed supervisory inspection which was part of its ongoing engagement with the investment firm sector. The inspection identified failings in the Firm’s anti-money laundering and countering the financing of terrorism (“AML/CFT”) framework. The breaches occurred between July 2010 and November 2016 and related to the following:
• Failure to conduct appropriate money laundering/terrorist financing (“ML/TF”) risk assessment.
• Failure to adopt adequate policies and procedures for preventing and detecting ML/TF.
• Failure to monitor and scrutinise customer transactions.
• Failure to provide training to staff on identifying suspicious transactions.
• Failure to ensure that all necessary arrangements were in place with third parties whom the Firm relied on to conduct customer due diligence measures on the Firm’s customers.
The Central Bank confirms that the Firm took the necessary steps to rectify the failings that gave rise to the breaches by 9 August 2018 and that the investigation is now closed.