December 9 2016
Settlement Agreement between the Central Bank of Ireland and Bray Credit Union Limited
The Central Bank of Ireland (the “Central Bank”) has fined Bray Credit Union Limited (“Bray Credit Union”) €98,000 and reprimanded it for breaches of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the “CJA 2010”). All of the breaches (save for one) persisted for 5 years and 7 months, and have been admitted by Bray Credit Union.
- Policies and Procedures: failure to adopt adequate policies and procedures, in particular in relation to customer due diligence, transaction monitoring, suspicious transaction reporting, training and record keeping;
- Customer Due Diligence: failure to conduct adequate customer due diligence on certain new and existing members;
- Monitoring Dealings with Customers: failure to monitor and scrutinise member transactions;
- Monitoring and Management of Compliance with the CJA 2010: failure to adopt policies and procedures to monitor and manage compliance with, and the consistent internal communication of, policies required under the CJA 2010; and
- Record Keeping: failure to retain certain records required under the CJA 2010.