CBOI New Registration for AML

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.


  • 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.