This document provides guidance to credit unions on anti-money laundering and countering the financing of terrorism requirements. It discusses the background and regulations credit unions must comply with, including customer due diligence, reporting suspicious transactions, and taking a risk-based approach. The deadline of March 31, 2017 for credit unions to submit their first statutory report on anti-money laundering measures is emphasized. Recent inspections found credit unions need significant improvements to comply with legal obligations in this area.

1. DO YOU KNOW YOUR MEMBERS?
Credit Union Guidance
Anti-Money Laundering/ Countering the Financing
of Terrorism and Financial Sanctions

2. Table of Contents
Credit Unions and AML/CFT - Reporting Deadline Approaches _________Page 1
AML/CFT/FS – The Background _______________________________________Page 2
Credit Unions and AML/CFT __________________________________________Page 6
Credit Unions and AML Compliance Where we are now _______________Page 9
Risk-Based Approach ______________________________________________Page 11
Senior Management Responsibility and Internal Controls _____________Page 13
Customer Due Diligence (CDD) _____________________________________Page 14
Reporting _________________________________________________________ Page 16
How StubbsGazette Can Help_______________________________________Page 17
Appendix: Glossary ________________________________________________Page 21

3. Credit Unions and AML/CFT - Reporting Deadline Approaches
or some time financial firms have been feeling the heat from ever more stringent
regulatory pronouncements with regard to anti-money laundering (AML) and
countering financial terrorism (CFT) requirements. For credit unions in particular, the
date 31 March 2017 has particular significance in that regard as for the first time they
will have to issue a statutory report on the measures they have adopted to counter
money laundering and related areas.
But that deadline should not confuse credit union officers as to their responsibilities
now. The 31st March 2017 is a reporting deadline (see below). In fact, credit unions are
already required to have in place a comprehensive system of policies and procedures
to counter money laundering and terrorist financing or officers risk severe punishment.
F
Report on Anti-Money
Laundering/Countering the Financing of
Terrorism and Financial Sanctions
Compliance in the Irish Credit
Union Sector
Page 1
Credit unions should be aware that they will be required to confirm annually
that they have put in place appropriate measures to address the expectations
outlined in the Report. This confirmation will be requested as part of the
Anti-Money Laundering section of the 2016 Credit Union Annual Return due for
submission to the Central Bank by 31 March 2017 and subsequent annual
returns.

4. AML/CFT/FS – The Background
inancial institutions worldwide have for years been grappling with escalating
regulatory obligations in the area of Anti-Money Laundering (AML), Countering
Financial Terrorism (CFT) and Financial Sanctions (FS).
F
The most infamous case to date of rank failure
to observe international AML/CFT requirements
is undoubtedly that of HSBC. In 2012 the world’s
largest bank was fined a record USD1.92 billion
by the US authorities for its role in aiding money
laundering by various Mexican drug cartels.
This came after HSBC Suisse was fined just over
USD30 million by the Swiss authorities for
“organizational deficiencies” that enabled its
clients to launder cash.
Money laundering is not a victimless crime. Criminality and associated money
laundering “have a corrosive, corrupting effect on society and the economic system
as a whole”, according to the IMF. To take one example, the effects of criminality and
laundering can be readily gauged by the fact that some 25% of African states’ GDP is
estimated to be lost to corruption each year.
Page 2
A RBA to AML/CFT means that financial institutions8 are expected to identify,
assess and understand the ML/TF risks to which they are exposed and take
AML/CFT measures commensurate to those risks in order to mitigate them
effectively.
Source: FATF – Financial Action Task Force

5. Page 3
In tandem with international efforts, the Irish government and the Central Bank have
ramped up legislation considerably in recent years. The Criminal Justice (Money
Laundering and Terrorist Financing) Act of 2010 (CJA 2010) is the bedrock that brought
the EU’s Third Money Laundering Directive into law. Next year these requirements will
be extended by the implementation of the 4th EU Money Laundering Directive
(MLD4).
CJA 2010 sets out legal provisions to ensure technical compliance and effective
implementation of international standards relating to AML and CFT. In the words of the
Central Bank the Act:
Defines broadly the offence of money laundering.
Defines designated persons and beneficial owners that come under the
provisions of the Act.
Provides for Directions, Orders and Authorisations relating to investigations.
Sets out customer due diligence, reporting, internal policies and procedures,
training and record keeping requirements of designated persons.
Provides for monitoring of designated persons.
The leaked files mention hundreds of Irish companies and individuals who hold
assets here or abroad by way of entities located in offshore jurisdictions
Source: Colm Keena – Irish Times April 2016

6. More focus on senior management (the board of the credit union) responsibility for
anti-money laundering (AML) and combating the financing of terrorism (CFT)
controls, including personal liabilities.
More focus on a risk based assessment of the credit unions AML/CFT threats and the
management of those threats through adequate policy.
More focus on the ongoing monitoring of members as part of “customer due
diligence” (CDD) which goes beyond simply identifying members.
Identification of the beneficial owner on all accounts and establishing if a member
is acting on their own behalf, including identifying the beneficial owner in all school
schemes, clubs and societies.
Introduction of “enhanced due diligence” (EDD) or specific controls for higher risk
circumstances.
Introducing the notion of a “politically exposed person” (PEP) as a higher risk
category of member.
The requirement to identify members where doubts exist as to “the veracity of
previously obtained documentation” – therefore the identification of all active
members over time.
The requirement to train all board members as well as relevant officers in the credit
union.
Page 4
More specifically, the new provisions of the CJA 2010 as they relate to AML/CFT
include:

7. Introduction of a stricter and more enforceable standard for the reporting of
suspicions. This is an objective test of suspicion – i.e. a definition of being “reckless” as
to whether or not property represents the outcome of criminal conduct and
requiring a report to be made if there are “reasonable grounds” for having a
suspicion, i.e. would a reasonable person have been expected to make a report in
the circumstances.
Clear identification and extension of the Central Bank’s powers to effectively
monitor and take measures, (including administrative sanctions) necessary to ensure
compliance with the CJA 2010 which is specifically applied to credit unions.
The Central Bank continues to be diligent in its AML/CFT actions and most recently
issued its report on Anti-Money Laundering, Countering the Financing of Terrorism and
Financial Sanctions Compliance in the Irish Funds Sector in November last year.
Page 5
It is very important to note that the new provisions of MLD4 expand the definition of
a PEP to cover domestic or resident PEPs. In other words Credit Unions are required
to determine whether or not a member or beneficial owner connected with the
member or service concerned is a PEP or an immediate family member or a close
associate of a PEP.

8. Credit Unions and AML/CFT
ecause membership of a credit union is
restricted to those individuals who fulfil a
specific qualification which is appropriate to
the credit union (the “common bond”)
there is an assumption that each credit
union is on more intimate terms with its
membership. The common bond is
recognised by the Central Bank as
“fundamental to the regulatory regime for
credit unions.”
B
The Central Bank also recognises that a credit union
offers primarily savings and loan products to its local
or associational community, with limits on the level of
savings an individual member can hold in the credit
union, which are specified by the Central Bank. There
are rules governing a credit union’s lending activity
which are also specified by the Central Bank.
In the words of the Central Bank, credit
unions therefore presently operate
within a restricted, often localised
market, providing, at present, simpler
financial services to members, not to
the public at large. Typical credit union
financial products and their community
ethos do not deliver sufficient
functionality or flexibility to be the first
Page 6
choice for large scale money launderers
and terrorist financiers. However, the
Central Bank goes on to say, “this is not to
say that credit unions have no risk of money
laundering or terrorist financing.” In
particular, the Bank notes the high level of
cash transactions which are typical of
credit unions.

9. In its Sectoral Guidance Note for Credit Unions on CJA 2010 the Central Bank identifies
a number of higher risk activities that should alert credit union officers to the potential
for money laundering and financing of terrorism.
Money transfers to unknown third parties.
Large one off transactions, particularly in cash.
Third parties paying in cash on behalf of the member.
Unusual loan or saving transactions such as larger loans made out to cash or to
unexplained third parties.
Large loans with unexplained short repayment schedules, or the acceleration of
the agreed repayment schedule on larger loans (borrow clean, repay dirty).
Reluctance to provide documentary evidence of identity when opening an
account (even when taking into account financial exclusion issues).
Page 7

10. Three Stages of Money Laundering
The stages in the Money Laundering process are well recognized
Placement is placing the proceeds of criminal activities in the financial system.
Layering is the conversion of the proceeds of criminal conduct into another
form and creating complex layers of financial transactions to disguise the audit
trail and the source and ownership of funds. This stage may involve transactions
such as loans or investments and very often may have an international
dimension, i.e. conversion of currency or transfers abroad.
Integration involves placing the laundered proceeds back in the economy to
create the perception of legitimacy. This may involve purchase of high value
goods or property
Page 8
The Bank recommends Credit Unions exercise extra vigilance in the following situations:
The excessive presentation of third party cheques or drafts by members.
Members taking out larger loans – where funds would seem more readily
available and the transaction seems economically
unviable.
Services provided to cash generating businesses,
including due care when accepting cash from local
businesses, that it represents the true turnover of the
business.
Accounts open with unusual versions of name, or
bogus or false names, or requests for multiple accounts
for a single member.
Use of, or requests for, large amounts of high
denomination notes (€200 & €500).
Significant unexplained foreign exchange activity.
Significant activity in children’s accounts where it would seem unreasonable that
the child was the beneficiary, (i.e. parents using children’s accounts for
significant transactions).

11. Credit Unions and AML Compliance – Where we are now
In May 2015 the Central Bank issued its Report on Anti-Money Laundering/Countering
the Financing of Terrorism and Financial Sanctions Compliance in the Irish Credit Union
Sector.
The Report was the outcome of a series of on-site inspections carried out by the
Central Bank and supplemented by Risk Evaluation Questionnaires submitted to the
Central Bank for evaluation. Its findings were overwhelmingly negative.
“The number and nature of issues identified during the inspections of the credit union
sector suggest that credit unions in Ireland need to significantly improve their AML/CFT
policies, procedures, systems and controls to ensure compliance with the CJA 2010,”
the Bank reported.
Failure to implement the requirements of the CJA 2010 in a timely manner.
Lack of oversight of AML/CFT issues at Board level;
Inadequate policies, procedures and processes in relation to Customer Due
Diligence (CDD) for new and existing members, on-going monitoring and
classification of risk;
Engaging in non-standard practices without appropriate Board oversight and
approval and without proper policies, procedures and systems and controls in
place. For example, accepting large cash lodgments from local businesses, or
lodgment of business proceeds to members’ personal accounts, without
considering and documenting any risks associated with these practices or any
additional due diligence or on-going monitoring requirements which may apply;
Lack of documented procedures to identify and verify beneficial owners where
warranted, for example in the case of business customers, clubs and societies
etc.;
Among the issues identified by the Bank were:
Page 9

12. Non-adherence to stated AML/CFT policies;
Failure to conduct adequate Money Laundering/Terrorist Financing risk
assessment of the business;
Failure to have adequate systems and controls, procedures and documentary
evidence of on-going monitoring of transactions;
Failure to define Politically Exposed Persons (PEPs) within policies. Lack of systems
and formal processes for identifying, verifying and monitoring PEPs;
Failure to ensure the provision of appropriate training to the Board members,
staff and volunteers at all levels, as well as enhanced training for staff in key
AML/CFT and FS roles;
Inconsistent and/or undocumented approaches for the reporting of Suspicious
Transaction Reporting (STR) by staff to the Money Laundering Reporting Officer
(“MLRO”), or the process for onward reporting to the relevant authorities.
Lack of a documented timeframe for reports to be received and reported and
failure to reference the penalties for not reporting or the offence of ‘tipping-off’
within the AML Policies.
Page 10
It is very important to note that the new provisions of MLD4 expand the definition of
a PEP to cover domestic or resident PEPs. In other words Credit Unions are required
to determine whether or not a member or beneficial owner connected with the
member or service concerned is a PEP or an immediate family member or a close
associate of a PEP.

13. Risk-Based Approach
Under CJA 2010 credit unions are required to apply a risk-based approach to AML that
ensures that its strategies “are focused on deterring, detecting and disclosing risks of
money laundering or terrorist financing in the areas of greatest perceived
vulnerability.” The steps it takes should be documented in a formal policy statement
“which assesses the most effectual and proportionate way to manage these money
laundering and terrorist financing risks.” These steps must include:
Identifying the money laundering and terrorist financing risks that are relevant
to the credit union.
Assessing the risks presented by the credit union’s particular:
Members
Products
Delivery channels
Geographical areas of operation.
Identification and
categorisation of higher risk
members. (S. 37 & S.39)
Designing and implementing
controls to manage and
mitigate these assessed risks.
Monitoring transactions,
including the large, complex
or unusual. (S. 54(3))
Recording appropriately what
has been done and why.
Page 11

14. Money Laundering/Terrorist Financing Risk Assessment
Page 12
Member
Standard Lower Risk Medium Risk High Risk
Well known established
members
Adequately identified new
members
Non domestic PEPs.
Members of Sanctions List (these
accounts must be frozen!)
(These accounts likely to be rare
in credit unions but must be
checked)
Less well known members. Possible gaps in
identification. i.e. out of date address
information. Pre 1995 members. Domestic
PEPs where known.Cash intensive
businesses; i.e. pubs, service stations,
gambling firms, dealers in high value
goods (car dealers, jewel, art & antique
dealers)
Product or
Service
Simple low value savings
and loan products
General Insurances
More complex very high value
type products/services, i.e.
wealth management,
correspondent banking, complex
trust or company structures.
(These products not currently
offered by credit unions)
Larger transactions, larger share balances
and loans. More complex products/
services; ultimate beneficiary may not
always be clear.
Foreign dimension; use of payment
service provider, i.e. Western Union or
provision of substantial foreign exchange
Delivery
Channel
Direct to member Members not identified face to
face Internet only business
(Not currently offered by credit
unions)
Not always face to face; use of telephone
and Internet. Payments to 3rd parties, i.e.
loan cheques made out to 3rd parties, or
receipts by one member into multiple 3rd
party accounts.
Geography
Not close to Border/Port
No Foreign Exchange
Funds to or from high risk
jurisdictions: see FATF list of
jurisdictions
(Rare in most credit unions)
Foreign exchange or alternative
remittance system used extensively.
Areas that are known to have high levels
of criminality or terrorist activity
Actions
Required
From credit
Union
Standard Identification;
OK to use exceptional
cases ID, i.e. in cases of
financial exclusion
Minimal ongoing
monitoring required
Enhanced Due Diligence
Required; Identify source of
wealth or funds along with
Standard Identification.
Detailed ongoing monitoring
required Sign-off from Board may
be required before relationship is
permitted.
Standard identification; but take care if
relying on exceptional cases ID alone.
Ongoing regular monitoring required; i.e.
reports of transactions/balances lodged
over certain thresholds
Source: Central Bank of Ireland

15. Senior Management Responsibility and Internal Controls
Page 13
The board in conjunction with management must ensure suitable controls are designed
and implemented which must include:
The credit union’s AML/CFT policy should be reviewed on at least an annual basis. In
addition “qualified parties who are independent of the implementation of the credit
unions AML compliance programme (such as internal audit, external audit or external
professionals) may be engaged to review AML/CFT policy and procedures to ensure
they are set-up and operating effectively.”
Credit unions should allocate to an officer (likely to be the new Compliance Officer -
who may or may not also be the money laundering reporting officer, MLRO) overall
authority within the credit union for the establishment and maintenance of effective
anti-money laundering systems and controls. One of the key tasks of this individual
should be the drawing up of an annual report to the Board on the operation of the
credit union’s AML/CFT systems and procedures providing a reasoned assessment of
the credit union’s compliance with AML/CFT legislation and guidance.
A formal AML/CFT risk assessment.
Customer Due Diligence measures including adequate identification of all
members and identification of beneficial owners and Politically Exposed Persons
(PEPs).
On-going member monitoring procedures including identification of complex or
large transactions and unusual patterns of transactions that have no apparent
economic or visible lawful purpose.
Reporting of all suspicions.
Training of all relevant officers, including all directors.
Record keeping.
Policies and procedures for the monitoring and management of compliance with
the Internal communication of the policies and procedures above.

16. Customer Due Diligence (CDD)
Page 14
The CJA 2010 requires that CDD be applied to existing customers where there exist:
“reasonable grounds to doubt the veracity or adequacy of documents or information
previously obtained for the purposes of verifying the identity of the customer.”
This Central Bank acknowledges that this obligation presents “significant practical
problems for credit unions” particularly in obtaining and verifying new identification
information in relation to existing members. The Bank specifies those members who
may have joined before the implementation of the original Criminal Justice Act, 1994
and were therefore exempted at the time from obtaining and verifying identity.
Nonetheless, the Bank recommends that a credit union reviews appropriate
identification data held for an existing member in the following trigger circumstances:
The credit union’s risk-based assessment of its business indicates that the member
in question falls into a higher than standard risk category, such as when moving to
a higher risk product or service.
A member looks for a new product or
service, i.e. a new loan application,
or moves to a new type of account.
The member’s account has been
previously inactive for a certain
period of time where this is unusual
for the nature of the service being
provided.
A transaction of significance takes
place, such as a large lodgment or
withdrawal.
Doubt has arisen in the normal course of business in relation to previously obtained
documentation or information.
Doubt has arisen in the normal course of business that the member, contrary to
previous information, is acting on their own behalf.
The credit union has any suspicion that the member may be involved in money
laundering or terrorist financing.

17. Page 15
Inevitably, most of the focus on CDD falls
with new members. And this is even more
focused in the case of Politically Exposed
Persons (PEPs) who must be subjected to
enhanced Due Diligence procedures. At
present, a PEP is understood to be a
foreign national who has in the previous
year held a prominent public function.
But MLD4 is set to extend the
requirements around PEPs significantly.
MLD4 clarifies the definition of a politically
exposed person (PEP) and widens the
categories of individuals who can be
regarded as PEPs to include members of
the governing bodies of political parties,
and directors, deputy directors and
members of the board or equivalent
function of an international organisation.
Most importantly, the rules relating to PEPs
are also extended to cover domestic
PEPs. MLD4 requires that, when a person
ceases to be a PEP, an Obliged Entity
must consider the continuing risk imposed
by that person for at least twelve months.
Risk-sensitive measures must be applied
until that person is deemed to pose no
further risk specific to PEPs. Furthermore,
Obliged Entities are not entitled to rely
exclusively on PEP lists, they are
responsible for making their own
determination as to whether a customer
is a PEP, or associated with a PEP.
The RBA is not a “zero failure” approach; there may be occasions where an
institution has taken all reasonable measures to identify and mitigate AML/CFT
risks, but it is still used for ML or TF purposes.
Source: FATF – Financial Action Task Force

18. According to Central Bank guidelines, all staff and volunteers need to know the credit
union’s internal reporting process, so that they know how to report suspicious activity.
In credit unions, reports will be made directly to the MLRO. Credit unions are urged to
consider a reporting template in which to standardise and simplify the internal
reporting process.
Reporting
The Central Bank deems the role of the MLRO
as central to the credit union’s AML/CFT
reporting process. The credit union must
appoint an officer as MLRO whose legal
responsibility it is to receive and act upon
suspicion reports.
Page 16
The guidelines issue the folowing checklist to determine the merit of making a report:
Does the transaction make sense in the context of the member’s business or
personal activities?
Is the size of the transaction expected or usual?
Is the transaction out of proportion to the normal expected income and
expenditure of that member?
Has there been a recent significant change in the pattern of transactions?
Is the total value of a series of transactions substantial?
Is the pattern of repayments on a loan consistent with the member’s earnings?
Are there many transfers to high-risk jurisdictions without reasonable
explanation?
Reporting

19. Page 16
To make sure you can stand over your statutory AML/CFT report by 31 March 2017,
Stubbs Gazette has marshalled its resources to provide the credit union movement
with a systematic, integrated suite of tools and media. Remember, this is not for some
future AML/CFT requirement, this is for current AML/CFT regulatory requirements.
This comprises our Enhanced Customer Due Diligence system (ECDD), four staggered
workshops to cover all of your requirements, in-house and external training and a
certified exam prior to D-Day
Workshop 1 – comprises a review of the Central Bank report.
Workshop 2 – the 3 Ps – Policies, Procedures, Processes.
Workshop 3 – Reporting suspicious transactions and the role of the MLRO.
Workshop 4 – Preparing for an AML/CFT Audit.
How StubbsGazette Can Help
2016 2017
Today
Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2017
Workshop 1 - Review Central Bank Report
3/31/2016
Workshop 2 - The 3 P's - Policies,
Procedures, Processes
6/16/2016
Workshop 3 - Reporting STRs, Role of MLRO
9/15/2016
Workshop 4 - Preparing an AML/CFT
Audit
11/17/2016
3 day course & Exam
12/1/2016
Switch on ECDD - Enhanced Customer Due Diligence System2/1/2016 - 4/14/2016
3/10/2016 - 4/30/2016
4/15/2016 - 6/1/2016
6/16/2016 - 7/7/2016
Batch match all members - existing and dormant
Classify High Risk Members
Switch on monitoring and alerting for HRMs
In house training for all staff
Online interactive classes5/1/2016 - 12/15/2016
In house training
for all staff
Daily Monitoring
of PEP/Sanction
Lists
Credit Union
AML/CFT/FS Compliance
A Risk Based Approach
4/15/2016 - 6/23/2016
12/16/2016 - 1/11/2017
Page 17

20. Page 18
The Central Bank findings give an indication of the challenges faced by Credit Unions
in satisfying the AML/CFT requirements of the Central Bank. StubbsGazette is pleased
to have for some time been a key source for financial institutions intent on verifying
their clients’ bona fides and legitimacy and now we have massively expanded the
scope of our search facilities to assist financial institutions in meeting their regulatory
obligations in AML/CFT,
Due Diligence – what you need to know
Under the provisions of The Criminal Justice (Money Laundering and Terrorist
Financing) Act of 2010, ‘designated persons’ within Credit Unions are responsible
for customer due diligence, reporting, internal policies and procedures, training
and record keeping requirements.
StubbsGazette‘s Enhanced Customer Due Diligence service at a stroke removes
the most onerous aspect of the new obligations. This online service gives credit
union officers the ability to verify in real-time the existence or otherwise of the
following categories of individuals within the credit union customer base:
Persons of Special Interest (SI): Individuals assigned Special Interest status due to
their involvement in selected criminal activities such as fraud, money laundering,
trafficking, terrorism, corruption or organized crime.
Politically Exposed Persons (PEPs): A person who is, or has at any time in the
preceding 12 months been, been entrusted with a prominent public function.
Relative or Close Associate (RCA): The PEP definition is extended to include family
members and known close associates of a PEP. Likewise for RCAs of Special
Interest persons.
Sanctions Lists (SAN), Other Official Lists (OOL), Other Exclusion Lists (OEL)
Risk & Compliance profiles contain the names of individuals, companies,
organisations, aircraft, banks and vessels contained in over 900 current
international official lists covering 60 jurisdictions. Lists published by the U.S. Office
of Foreign Assets Control (OFAC), the United Nations and the European Union are
included.

21. Page 19
StubbsGazette will be making available to its subscribers a comprehensive database
specifically designed towards providing background checks to identify potentially
compromised individuals for the purposes of anti-money laundering and countering
the financing of terrorism. Specifically, the following categories will be highlighted.
Heads & Deputies State/National Government Presidents,Taoiseach etc.
National Government Ministers This category contains a country’s government
ministers, for example, Minister of Finance, Minister of Foreign Affairs etc.
Members of the Dail, Seanad, Stormont Assemby etc This category contains
members of the bodies/assemblies making up the national legislature
Senior Civil Servants–National Government This category contains the
uppermost levels of the regional civil service. Titles vary depending on the
country concerned, but include those like Secretary General etc.
Embassy and Consular Staff, the top two positions at a country’s foreign
representations and the top position at a country’s consulates.. Senior Members
of the Defence Forces. Senior Members of the Police Services (Garda Siochana,
PSNI). Senior Members of the Secret Services
Senior Members of the Judiciary
State Corporation Executives, State Agency Officials, Heads & Deputy Heads of
Local Government, Religious Leaders, Political Party Officials. International
Organisation Officials
City / Town Mayors,Political Pressure and Trade Union Officials
International NGO Officials, Local Public Officials, Local Councillors etc.
International Sporting Organisation Officials
Relatives or Close Associates (RCA)
Special Interest Persons (SIPS) – individuals involved in selected criminal activities
such as fraud, money laundering, trafficking (of people, drugs weapons and/or
other items), terrorism or supporting terrorism, corruption and/or organized crime
A Politically Exposed Person can also be catagorised as a SIP if such a person is
involved in one or more of the above activities.

22. Page 20
‘Batch match’ your existing customer base
Provide real-time verification and validation at customer onboarding stage
Deliver ongoing monitoring and reporting, particularly of higher risk customers
StubbsGazette ECDD service will give you the comfort you need to ensure you satisfy
all aspects of the Central Bank’s customer due diligence requirements with immediate
practical effect. The service will immediately:
ECDD is just the beginning of a suite of new services designed to equip Credit Unions
with the tools they need for the new AML/CFT regime. Beginning in April 2016,
StubbsGazette will host a series of workshops and to ensure subscribers will have in
place robust policies and procedures to satisfy Central Bank requirements before the
March 31 2017 deadline date.
In addition, StubbsGazette will put in place a robust credit union AML training regime
to allow credit unions satisfy Central Bank requirements.
It is an offence not to train credit union personnel in their AML/CFT
obligations. A successful defence by a staff member or volunteer of not
having been trained could make the credit union itself guilty of the money
laundering offence. Penalty on conviction for not training is a fine or
imprisonment for a term not exceeding five years, or both.
Central Bank Guidance Note for Credit Unions, CJA 2010

23. Page 21
AML Anti-Money Laundering
CDD Customer Due Diligence
CFT Countering the financing of terrorism
CJA 2010 The Criminal Justice (money Laundering and Terrorist Financing) Act 2010
DPC Data Protection Commissioner
ECDD Enhanced Customer Due Diligence
FS Financial Sanctions
ID&V Identify & Verify
IFB Irish Fraud Bureau
MLD4 The 4th Money Laudering Directive
MLRO Money Laundering Reporting Officer
OOL Other Official List
PEP Politically Exposed Person
RBA Risk Based Approach
RCA Relative & Close Associate
SCD Simplified Customer Due Diligence
SI Special Interest Person
SI-LT Special Interest Person (Lower Threshold)
SOF Source of Funds
STR Suspicious Transaction Report
TF Terrorist Financing
GBFI Garda Bureau of Fraud Investigations
Appendix Glossary

24. If you have any further questions please do not hesitate to
contact us on +353 1 6725939 or email info@stubbsgazette.ie