On Nov. 27, CBOI issued rules for firms to register for AML.
- New requirement for unregulated firms to register with CBOI re AML oversight.
- Per criminal justice (money laundering, terrorist financing), (amendment) act.
- If firm offers specified service, not otherwise authorised for business by CBOI.
- Guidance specifies leasing, factoring, safe custody and other services effected.
Lending and Leasing
- Lending: consumer credit, credit agreements re immovable property, factoring,
with or without recourse, financing commercial transactions, include forfeiting. - Financial leasing, payment services per EU PSD; guarantees and commitments.
- Issuing and administering other payments, travellers’ cheques, bankers’ drafts.
Own Account Trading
- Trading for own account, or for account of customers, in any specified product.
- Money market instruments, including cheques, bills and certificates of deposit.
- Foreign exchange; futures adoptions; exchange and rate products; securities.
Advice and New Issues
- Participation in security issues, service, advice to firms on structure, strategy.
- Advice and services relating to mergers and the purchase of other companies.
- Money broking; portfolio management/advice; safekeeping, custody; e-money.
Effectiveness
- From Nov. 26 2018, firms offering certain services required to register re AML.
- Guidance on how firms register as a Schedule 2 Firm, with a registration form.
- Separate guidance notes that assist the firm to complete the registration form.
