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Irish SPVS And Schedule 2 AML Compliance Obligations - Government, Public Sector

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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