ACAMS Members in Ireland can register to become Ireland Chapter members by clicking here. No Chapter fees will apply for 2016 events.

ACAMS Ireland Chapter members are made up from professionals at all levels and industries, and government areas working across a multitude of functional areas, within SMEs, Irish Companies and large multi-nationals that operate here in Ireland. The group shares a common interest ‘the effective prevention and detection of all Financial Crimes including but not limited to, money laundering and terrorist financing’.

The mission of ACAMS Ireland Chapter is to provide an environment that facilitates members working together, sharing their previous experiences and collective expertise, to try and overcome and resolve some of the AML/CTF and Sanctions-related trends, regulatory changes our businesses & industries are presented with on a day to day basis as they conduct trade and enterprise here in Ireland and globally.

The ACAMS Ireland Chapter welcomes all professionals to join and become members, who deal with or have an interest in AML/CTF, this is not just limited to employees of compliance. This will allow us to organize learning, education and networking opportunities that will foster and promote the exchange of ideas and information amongst all business professionals who work with, or work alongside or have an interest in, AML/CTF.

The ACAMS Ireland Chapter will bring in topical speakers and run open events that will present relevant and useful information to aid all members in growing their knowledge base and understand recent changes and trends. The ACAMS Ireland Chapter will also hold events for the purpose of getting our local AML/CTF community together to share ideas and insights pertaining to Best Practice and also the Financial Crime topics of the day.

The ACAMS Ireland Chapter believes the need to meet and share knowledge is especially pertinent given ever evolving technologies to move money, and the many cross-jurisdictional impacts of legislative controls. We encourage membership from all sectors (Banking; Insurance; Credit Unions; Payments; Funds; Regulators; Law Firms; New Technologies; Fin-tech etc.) and all professionals that maintain an interest in or professional involvement with the detection and prevention of Financial Crimes (Compliance, Operations, Technology, Sales, Operational Risk, Internal Audit, Legal Practices, Finance, etc.).

Upcoming Ireland Chapter learning events will be announced soon.

Global Sanctions Recent Changes

ACAMS Ireland Chapter had our second Chapter Educational Event on the 15th of September 2016 where recent changes in global sanctions regimes were discussed.

  • Chris Martin (Eversheds) gave a very engaging overview of current environment and provided specific clarity around changes to the sanctions regime as it relates to Iran.
  • Finn Plekkenpol (Airbnb) spoke to attendees about Cuba – specifically the impact of the embargo; Casa Particulares and the hoped-for removal of the embargo in future.
  • Mark Bonham (Airbnb) provided a more in-depth look at the changes that are taking place in relation to the embargo and shared some of the footage from the recent visit by Barack Obama to Cuba with representatives of US commercial enterprises – including Airbnb Co-Founder Brian Chesky.
  • Rob Duncan (RDC) closed off the presentations by giving some background to RDC and some details around products they provide.

Participants were then invited to enjoy the refreshments provided by Airbnb Food Team that were kindly sponsored by RDC. ACAMS Ireland Chapter would very much like to thank RDC who sponsored the event and all of the team in Airbnb who looked after us all so well!

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4th AML Directive – Update and Impact on Irish Financial Services & Fintech

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The European Union’s Fourth Anti-Money Laundering Directive came into force on 26 June 2015. Member States must update their respective money laundering & terrorist financing laws and transpose the new requirements into local law by 26 June 2017.

With so much going on in EU financial services presently, including Brexit, it may be difficult to keep up with this extremely important area of law – at Board level, senior management, MLRO, Heads of Compliance and other staff involved in the implementation and monitoring of anti-money laundering and counter terrorist financing.

Peter Oakes, the former Director of Enforcement and Anti-Money Laundering who established the Central Bank’s Enforcement Directorate and implemented its new strategy in 2010, is well placed to lead this critical and informative seminar on ‘4th AML Directive – Update and impact on Irish Financial Services & Fintech’. Peter will leverage his local Irish and international work in financial services and fintech to give the audience a broad flavour of the AML/CFT issues which designated persons face when doing business within Ireland and across the European Union.

Without limiting the areas covered, Peter will highlight to finserv and fintech firms key aspects relating to the following:

  • Board and Senior Management Responsibility
  • Supervision and Enforcement
  • Policies & Procedures
  • Risk Assessments
  • Customer Due Diligence
  • Beneficial Ownership
  • Politically Exposed Persons
  • Suspicious Activity Reports
  • Record Keeping
  • Correspondent Relationship
  • Financial Intelligence Units
  • Home and Host Responsibilities

Speaker: Peter Oakes

Peter is a well-known and respected regulatory and fintech expert. He is regular commentator in Irish & international media and at international conferences on financial crime, governance, fintech, regtech and other central banking/regulation (click here). Peter is non-executive director a large MIFID technology options market maker (Ireland), advisory board member at ClearSettle (London) and advisory committee at Corlytics, Cogni and Plynk. Peter works in Dublin and London advising fintech and non-fintech companies (including banks, payments services, emoney, investment management, funds industry and intermediaries) on Central Bank of Ireland, Financial Conduct Authority and other EU regulator authorisation, money laundering/terrorist financing and other supervisory and enforcement matters. Peter is the former Director of Enforcement & Financial Crime at the Central Bank of Ireland and has worked in senior roles with the UK Financial Services Authority, Australian Securities & Investments Commission and the Saudi Arabian Monetary Agency. Most recently Peter was Board Director & Chief Risk Officer (& MLRO) in London for Bank of America Merchant Services (Europe), where he established the business and led its FCA authorisation. He is a lawyer qualified in Ireland, the United Kingdom and Australia. As many know, Peter is Founder of Fintech Ireland and also President of the Irish Chapter of the Irish Australian Chamber of Commerce which supports innovation initiatives between Australia and Ireland, and will inform and support the Australian EU FTA negotiations taking place in 2017.


Board Governance and the MLRO


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On the 21st April 2016, ACAMS Ireland Chapter, in collaboration with Citi who kindly hosted the event in their Dublin offices, held an event considering the challenges and pressures faced by both members of the Board and the MLRO reporting into that Board.

ACAMS Ireland Chapter was delighted to have Peter Oakes and Marcus Doherty discuss their experiences as members of various Boards and as a MLRO respectively. Following their presentations, Peter and Marcus engaged in a panel discussion with Elizabeth Henry (Co-Chair of the ACAMS Ireland Chapter).

  • Peter Oakes is Non-Executive Director of Irish regulated firms and Fintech firms. Until recently he was also Executive Director and CRO of Bank of America Merchant Services. Peter previously held a number of roles with various global regulatory bodies including being appointed the first Director of Enforcement & Financial Crime at the Central Bank of Ireland.
  • Marcus Doherty is the head of Head of Compliance and MLRO for Brown Brothers Harriman’s (BBH) Irish business. Prior to this Marcus was a Senior Member of the Financial Services, Regulation and Compliance Practice Group in A&L Goodbody Solicitors following 11 years in various roles with Bank of Ireland. Marcus is a respected contributor to discussions around AML and Compliance in Ireland and is closely involved with the Institute of Banking on the Professional Diploma in Compliance.
  • Elizabeth Henry is Head of AML, Sanctions and Anti-Bribery and Corruption (FCC) for HSBC Ireland and has over 14 years’ experience in the banking and financial services sector with a focus on Compliance. Before joining HSBC Elizabeth was Director of AML for Western Union Payment Services Ireland Limited following a number of years as a Compliance Manager for a Bank in Massachusetts, USA.

Cathal O’Daly, Director – Cross Currency Payments (Sales) at Citibank Europe plc, opened the event by welcoming the attendees and giving an overview of Citi’s growth in Ireland in the last 50 years. Cathal opined that there is a strong future for AML, Risk and Compliance roles in Ireland and therefore welcomed ACAMS for the opportunities it provided for staff development.

Elizabeth Henry gave some background on the ACAMS Ireland Chapter and its intentions in promoting the prevention and detection of financial crime amongst all interested professionals, not just those working in Compliance. Elizabeth then introduced the panellists and Peter Oakes took the podium.

Peter began by considering on what is meant by accountability within the regulations i.e. who might be considered an officer as well as where and how an offence might be committed. When dealing with Risk Governance and Monitoring, Peter noted how personal accountability for Officers is not just contained within the Criminal Justice Acts but also in the Companies Acts. Accountability around functions and activities outsourced to third parties was also flagged as a point of regulatory attention. Peter analysed some of the challenges facing MLROs and their immediate concerns. Peter concluded his excellent presentation by flagging the positive symbiotic relationship shared by Non-Executive Directors and MLROs when working on AML/CTF requirement of a designated entity.

Marcus noted that the ‘Dear CEO’ letter Peter had mentioned during his presentation had helped galvanise support and resources for AML/CTF within organisations. During his presentation Marcus sought to put the MLRO as a function in context. His wide-ranging and highly engaging presentation looked towards the legislative position of the MLRO, noting also the need for ongoing monitoring and critical function of reporting; the perceived distinction between Head of AML and MLRO; Policies & Procedures that should be in place (including a living AML Risk Management Strategy) and the function of MLRO in relation to the Board. When examining the Board Marcus looked towards their function but also where the lines of responsibility might lie i.e. oversight or execution and the management of the AML Risk Management Strategy. It was also noted that challenge or discussion by the Board should be welcomed and recorded to evidence their engagement with AML/CTF matters. The MLRO should in turn be in a position to challenge or escalate to the Board. When concluding Marcus examined the ‘supervisory liability’ of the Board and MLRO, especially in comparison with the US, noting the potential failure on a MLRO’s part might be the failure to maintain their independence.

Questions submitted by the attendees in the advance were then put to the panel.

When asked if the MLRO should be a PCF 15, Marcus was of the opinion that there was some merit to have the MLRO as a standalone PCF however there was the risk of over-complicating structures. Peter in turn put his response in the context of “Nature Scale Complexity” i.e. does the designated entity require or warrant a standalone MLRO? The panel also considered the definition of MLRO in the four recent sector reports issued by the Central Bank.

A query about the increase in use and ‘intelligence’ of technology was discussed by Peter in relation to Fintech and Data Analytics along with his positive personal experience of new automated systems for account opening.

On discussing the potential issues faced around Sanctions/ABC breaches being treated with the required gravity by designated entities Marcus noted that fines appear to have been raised where it appears things were previously known by the relevant parties. It was important, in his opinion, to have Board attention and to keep them informed. The MLRO should also be strategic and build relationships with Compliance Officer, other MLROs and the heads of Business. Escalation to Board of parent might be an option. Peter was of the opinion that the Board should be informed and potential similarities to administrative sanctions flagged. Additionally he was experiencing Boards challenging the MLRO and expecting more information.

Another attendee-submitted query asked the panel to consider how involved the MLRO might need to be with new business and products via risk assessments and other means. Marcus suggested that it was an opportunity for MLRO to get involved and provide space for discussion and an informed decision. Peter looked to the lack of written support for new lines and trends, citing the Central Bank sector reports, where MLRO should consider the emerging AML/CTF trends on similar products and provide counsel to the Board to ensure Risk Assessments are sufficiently robust.

The final query was whether Funds should have separate AML Policies from their service providers. Both Marcus and Peter were of the opinion that this should be the case.

Alexi Villedrouin, Global Product Manager at Citibank Europe plc, brought proceedings to a close by thanking organisers and panellists. Alexi raised the importance of innovation to Citibank throughout its 200 year existence and noting that the Innovation Lab was founded in Dublin in 2009 building on a past that included the first ATMs and the transatlantic cable. Alexi was of the opinion that without innovation financial services providers don’t have a future, however without AML/Compliance then they wouldn’t have innovation. In Alexi’s view AML/Compliance should be seen as trusted advisers and it was a real positive to host ACAMS given that ACAMS provides space for education and development.


AML/CTF Evening Networking Reception and VIP Presentations

ACAMS Celebrates Successful Launch of the Ireland Chapter

ACAMS was delighted mark the official launch of our Ireland Chapter with a networking reception at the Westin Dublin on 14 January 2016. Almost 200 AML/CTF professionals attended, representing Ireland’s largest financial institutions, international banks, funds and insurance sectors, law firms and FinTechs.

Thank you to all who attended to make this a successful event.

The evening of conversation, cocktails and canapes was a very warm welcome for ACAMS in Ireland, the latest of over 50 ACAMS Chapters to be established worldwide. The Ireland Chapter Board looks forward to hosting more informative and entertaining events in the coming months.

Event Highlights
Domhnall Cullinan from the Central Bank of Ireland said in his keynote speech that ‘the launch of a Chapter in Ireland will assist compliance professionals to better understand money laundering and terrorist financing risks’, and John Byrne (ACAMS Executive Vice President) spoke about the myriad of challenges for AML professionals in 2016.

Elizabeth Henry, HSBC Ireland and Co-Chair of the ACAMS Ireland Chapter said ‘The Chapter Board believes the need to share knowledge is especially pertinent due to ever evolving technologies to move money and cross-jurisdictional impacts of legislative controls. We welcome members from government organisations and across industry within SMEs, Irish companies and the large multi-nationals that operate here in Ireland.’

Angela Salter, ACAMS Head of Europe and CIS, said ‘The launch event verified the huge levels of optimism around the progress Ireland has already made, and demonstrated a clear sense that the country is on track to achieve the government’s goal of becoming an EU hub for banking and FinTech companies.’

Press Coverage
Download the full press release
Irish Independent article
RTE television interview with John Byrne (from 22:11)
RTE radio interview with John Byrne

This event was kindly sponsored by:

Bureau van Dijk   Finscan

Thank you to our speakers:

Domhnall Cullinan
  • Domhnall Cullinan

  • Head of the Anti-Money Laundering Division
  • Central Bank of Ireland

Domhnall has worked in the Central Bank of Ireland for more than 12 years and was appointed Head of the Anti-Money Laundering Division in June 2014. Prior to joining the Central Bank Domhnall worked for the Irish pensions regulator for 2 years having spent the previous decade working in the Life and Pensions industry.

He has been involved in the development of policy and legislation nationally and has represented Ireland internationally at the European Insurance and Occupational Pensions Authority and the Financial Action Task Force.

Domhnall is currently overseeing the AML/CFT risk assessment framework and supervisory engagement model for all financial institutions supervised by the Central Bank of Ireland.


John J Byrne
  • John Byrne

  • Executive Vice President
  • Association of Certified Anti-Money Laundering Specialists

John J. Byrne, Esq, CAMS is Executive Vice President of the Association of Certified Anti-Money Laundering Specialists or ACAMS. Byrne is an internationally known regulatory and legislative attorney and one of the leading AML voices for 30 years. He has experience in a vast array of financial service related issues, with particular expertise in regulatory oversight, policy and governance, anti-money laundering (AML), privacy and terrorist financing. He has written over 100 articles on AML, asset forfeiture and privacy; represented the banking industry in this area before the United States Congress, state legislatures and international bodies such as the Financial Action Task Force (FATF); and appeared on CNN, Good Morning America, the Today Show, and many other media outlets.

John has received a number of awards, including the Director’s Medal for Exceptional Service from the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the ABA’s Distinguished Service Award for his career work in the compliance field.

John is a graduate of Marquette University in Milwaukee, Wisconsin (1978) and the George Mason University School of Law in Arlington, Virginia (1983). John’s blog, “AML, Fraud and Other Things,” can be found at: www.bankingexchange.com as well as on the ACAMS website. He also hosts a podcast and you can follow him on Twitter @jbacams2011.


Kieran Beer
  • Kieran Beer

  • Editor-in-Chief
  • ACAMS MoneyLaundering.com

Kieran Beer, CAMS, joined Fortent in May 2006 to launch a new compliance news and legal research, Fortent Inform. With Fortent’s subsequent purchase of Alert Global Media in January 2007, Kieran became editor-in-chief and editorial director ACAMS moneylaundering.com, which incorporated Inform, Money Laundering Alert and moneylaundering.com.

Prior to joining what has become ACAMS, Kieran was executive editor of Bloomberg Wealth Manager, a trade magazine for financial advisers and family offices. He also served as a staff writer for Bloomberg Markets Magazine.

Kieran has been a financial journalist for more than 20 years, beginning his career at Institutional Investor, where he worked as a reporter and editor in the newsletter division and was a contributor to Institutional Investor magazine. He served as editor-in-chief of The Bond Buyer, founding editor of Thomson Municipal News/The Bond Buyer Wire and as the editor of the American Banker.

Kieran writes a column and periodically reports on money laundering and bank compliance. He has served as a panelist and moderator at industry conferences and appeared on CNN, CNBC, WCBS and spoken on NPR and Bloomberg radio (WBBR).


Angela Salter
  • Angela Salter

  • Head of Europe and CIS
  • Association of Certified Anti-Money Laundering Specialists

Angela Salter joined ACAMS in 2015 to lead the organisation’s development in Europe. A senior commercial executive with a strong track record in overseas market development, Salter has spearheaded the growth of several international businesses serving the financial services community including roles with Thomas Reuters, Vivendi, Hoppenstedt Bonnier, Moody’s and Financial Times.

Highly rated for insight, innovation and integrity Salter is respected as a builder of strong, mutually beneficial business relationships, and getting things done.


Elizabeth Henry
  • Elizabeth Henry

  • Co-Chair
  • ACAMS Ireland Chapter Board

Elizabeth has over 14 years’ experience in the banking and financial services sector with a focus on Compliance.

Currently as Head of AML, Sanctions and Anti-Bribery and Corruption (FCC) for HSBC Ireland, Elizabeth is responsible for implementing the Bank’s FCC strategies, policies and standards for HSBC. Elizabeth acts as the principal point of contact for internal and external stakeholders in relation to Financial Crime risk within Ireland.

Prior to joining HSBC, Elizabeth was Director of AML for Western Union Payment Services Ireland Ltd, with responsibility for the Agent Oversight Program. In this role Elizabeth was responsible for directing and developing risk based AML compliance programs. Elizabeth was involved in long- and short-term planning, in a highly diversified and changing environment. During this time Elizabeth was involved in a very successful European wide recruitment project to increase the number of compliance officers across the region executing the WUPSIL AML Program. Elizabeth spent over four years as a Compliance Manager for a Bank in Massachusetts, USA. During this time Elizabeth specialized in developing the AML program for the Bank. Elizabeth also worked in Citco Bank Nederland NV as Compliance Officer, in their Dublin office.

Elizabeth has earned her LCOI designations with the Association of Compliance Officers in Ireland, is a Certified Regulatory Manager with the American Bankers Association and has obtained her CAMS certification.


Therese Agnew
  • Therese Agnew

  • Co-Chair
  • Ireland Chapter Board

Therese is an EU AML Officer with over eight years’ experience, working with J.P. Morgan Chase Commerce Solutions a subsidiary of JP Morgan, in Dublin.

In her role she is responsible for Anti Money Laundering (AML) and Sanctions strategic initiatives and projects to meet regulatory obligations for the European business. Therese is a Certified Anti-Money Laundering Specialist (CAMS), a Part qualified Chartered Accountant (CAI) and holds a Professional Certificate in Compliance.


Therese Agnew

Therese Agnew
Co–Chair

Therese is an EU AML Officer with over eight years’ experience, working with J.P. Morgan Chase Commerce Solutions a subsidiary of JP Morgan, in Dublin.

In her role she is responsible for Anti Money Laundering (AML) and Sanctions strategic initiatives and projects to meet regulatory obligations for the European business. Therese is a Certified Anti-Money Laundering Specialist (CAMS), a Part qualified Chartered Accountant (CAI) and holds a Professional Certificate in Compliance.

Email: Therese.agnew@gmail.com


Elizabeth Henry

Elizabeth Henry
Co-Chair

Elizabeth has over 14 years’ experience in the banking and financial services sector with a focus on Compliance. Currently as Head of AML, Sanctions and Anti-Bribery and Corruption (FCC) for HSBC Ireland, Elizabeth is responsible for implementing the Bank’s FCC strategies, policies and standards for HSBC. Elizabeth acts as the principal point of contact for internal and external stakeholders in relation to Financial Crime risk within Ireland.

Prior to joining HSBC, Elizabeth was Director of AML for Western Union Payment Services Ireland Ltd, with responsibility for the Agent Oversight Program. In this role Elizabeth was responsible for directing and developing risk based AML compliance programs. Elizabeth was involved in long- and short-term planning, in a highly diversified and changing environment. During this time Elizabeth was involved in a very successful European wide recruitment project to increase the number of compliance officers across the region executing the WUPSIL AML Program.

Elizabeth spent over four years as a Compliance Manager for a Bank in Massachusetts, USA. During this time Elizabeth specialized in developing the AML program for the Bank. Elizabeth also worked in Citco Bank Nederland NV as Compliance Officer, in their Dublin office.

Elizabeth has earned her LCOI designations with the Association of Compliance Officers in Ireland, is a Certified Regulatory Manager with the American Bankers Association and has obtained her CAMS certification.


Paul Barry

Paul Barry
Treasurer
HSBC Ireland

Paul has 25 years of diverse experience as a CFO, risk professional and senior business manager in assurance, risk consulting and financial services for leading international organisations.

As Head of Business Implementation he is currently responsible for client on-boarding for the HSBC securities services business in Ireland, Bermuda, Cayman, Guernsey and the US, having previously been responsible for business planning. In addition, Paul has been In-Country Execution Lead for the rollout of global AML and Sanctions standards and a new financial crime compliance framework since 2014.

Formerly Global Equities CFO for JP Morgan’s securities services business based in London and CFO for their business in Luxembourg, Paul has also held senior finance and operations positions with the Bank of New York, Royal Bank of Scotland and ING Barings in Dublin. He has also worked in risk consulting and assurance with Andersen in both Dublin and New York.

Paul is a fellow of the Institute of Chartered Accountants in Ireland and graduated from Trinity College Dublin with an honours degree in Business Studies. He joined ACAMS in 2015 and is a CAMS certified member.

Email: paul_m_barry@hotmail.com


Mark Bonham

Mark Bonham
Membership Director
Airbnb

Mark is Payments Compliance Program Manager for Airbnb Ireland. Responsible for AML, Sanctions, ABC programs supporting both EMEA and APAC regional development, conducting program risk assessments and enhancements, money laundering and fraud investigations and compliance due diligence testing.

Mark has worked over 20 years in the international Reinsurance market in executive roles as Head of Compliance, Claims, Finance, and Treasury. Mark successfully established various start-up reinsurance undertakings in Ireland, UK and Bermuda and is a Chartered Director, Certified International Cash Manager and a member of ACAMS.

Email: mark.bonham@airbnb.com


Sana Khan

Sana Khan
Programming Director
Arista Networks Inc.

Sana Khan is a Commercial Contracts Attorney with Arista Networks Inc. She previously worked as a Legal Counsel with First Names Group, an international trust and corporate services business, where she had MLRO roles and was heavily involved in anti-money laundering matters and compliance remediation projects across Europe.

Sana is a qualified barrister and a lecturer in law (to postgraduate level). At the time of qualifying, she was the youngest practising barrister in the country. She has received numerous scholarships and awards at national and international level for achievements in legal matters including international moot courts and publications.

She has presented papers both nationally and internationally on the developments of governance standards in the banking and insurance industries. She lectures in a variety of subject matters including corporate governance (Griffith College Dublin), anti-money laundering, data protection and CSR in a number of organisations. She is also experienced in developing and delivering CPD training on anti-money laundering.


Oisin Kilgallen

Oisin Kilgallen
Co–Programming Events Director
DMS Bank & Trust Ltd

Oisin Kilgallen joined DMS Bank & Trust as an AML Associate in 2015. He works with teams based in Dublin, Hong Kong and the Cayman Islands to implement the AML/KYC policies and procedures of DMS Bank & Trust, especially those relating to Client onboarding. His role also involves assisting in the growth of the bank into new markets.

Prior to working with DMS Bank & Trust, Oisin held AML and Credit Analyst roles in J.P. Morgan Chase Commerce Solutions in Dublin (a subsidiary of JP Morgan). He has also held different operations positions within KBC Bank Ireland and Permanent TSB.

Oisin is a Certified Anti-Money Laundering Specialist (CAMS).

Email: okilgallen@dmsbank.com


Kevin Nolan
Board Member

Kevin Nolan joined Wells Fargo Bank International as the MLRO/Financial Crime Officer in 2015. Prior positions in AML/CTF and Compliance have included roles as Financial Crime Prevention Manager (Certus) and AML Compliance Manager for Ireland & Iceland (Western Union). Kevin is CAMS qualified, a member of the International Compliance Association and a Licentiate of the Association of Compliance Officers in Ireland.