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On 16 December 2020, the Central Bank of Ireland
(
Letter ) highlighting anti-money
laundering (
AML ) compliance issues
that Irish SPVs that are Schedule 2 Firms (so-called because they
carry out one or more of the activities specified in Schedule 2 of
the Criminal Justice Act 2010) should be monitoring with care.
Schedule 2 Firms would include, for example, Irish SPVs that are
involved in activities such as lending, debt factoring or finance
leasing.
Appendix A to the Letter sets out the CBI s findings, as
well as its expectations, in various categories.
Board Oversight and Governance
Firms should be able to demonstrate that AML is a regular agenda
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