Ireland Chapter


Upcoming Event

  • ACAMS Ireland Chapter: Reporting STRs to the Revenue
  • August 20, 2020
  • Presentation: 1:00 PM – 2:00 PM
  • 1 CAMS Credits
    * Only active ACAMS members in Ireland will receive the 1 CAMS Credit upon attendance of the entire event
  • Virtual Event
  • Read More | RSVP Here

The ACAMS Ireland Chapter formed in January 2016 and has since delivered over a dozen events tailored to our Irish market.

Members of the ACAMS Ireland Chapter are professionals from all levels and industries with a common interest in the effective prevention and detection of Financial Crimes. We welcome professionals with an interest in Financial Crimes to join our Chapter’s existing members from banking, insurance, payments, regulatory bodies, funds, law firms, fintech, and more.

Our mission is to provide an environment that encourages the exchange of ideas and information, and leverages our collective expertise, to address regulatory change and financial crimes trends. The ACAMS Ireland Chapter is committed to bringing regular events to Ireland with speakers focused on topical issues, such as GDPR, PSD2, and Board Governance. We also provide a forum for networking with other professionals and building on your own best practices, especially crucial in today’s complex regulatory environment.

Keep up to date with the Chapter:

  • ACAMS Ireland Chapter: Reporting STRs to the Revenue
  • August 20, 2020
  • Presentation: 1:00 PM – 2:00 PM
  • 1 CAMS Credits
    * Only active ACAMS members in Ireland will receive the 1 CAMS Credit upon attendance of the entire event
  • Virtual Event


ACAMS Ireland Chapter: Reporting STRs to the Revenue

Join the ACAMS Ireland Chapter for our second virtual session of 2020 to hear about the new online reporting of STRs to the Revenue, which will be submitted online via the Revenue Online Services (ROS). Aisling Haughey Suspicious Transaction Unit at Revenue, will talk us through the STR typologies that the Revenue receives, how the STR are used by the Revenue and will share best practices on how to generate a good STR. The session will then explain how to register to ROS and showcase how to use the online reporting system. Finally, there will be a discussion on the link between the ROS tool and GoAML, currently used to report STRs to the Garda Síochána.

Overview of STR
How Revenue makes use of STRs
What is ‘suspicious activity’
Good and Bad STRs
New System Development – Submission of STRs Online to Revenue
Questions and Answers

Please Note:
*only active ACAMS members in Ireland will receive the 1 ACAMS credit upon attendance of the entire event


  • Aisling Haughey , Suspicious Transaction Unit, Revenue
  • Therese Agnew, Head of Financial Crime, Utmost Group Ireland
  • Alessia Bräutigam, Senior Compliance Training Specialist (Level 3), PayPal

ACAMS Ireland Chapter: Responding to Regulatory Requests

Join us for our first virtual session of 2020, where we’ll discuss processes and strategies for dealing with ad hoc regulatory queries or requests, with particular focus on AML/CFT and Financial Sanctions. Matheson’s Joe Beashel will kick us off with best practices and frameworks for communication, handling incoming requests, and escalations, while also touching on crises and incident management. We’ll then share anonymized results received from an illustrative sample of leaders across retail banking, corporate banking/foreign direct investment, funds, fintech, and insurance on their own experiences, forming a view of the approach taken by Ireland’s regulated entities.

Please Note:
* only active ACAMS members in Ireland will receive the 1 ACAMS Credit upon attendance of the entire event


  • Joe Beashel – Regulatory Risk Management Partner, Matheson
  • Kevin Nolan – Global Head of Financial Crime & Sports Integrity, Flutter Entertainment Plc

Event Sponsor:


Download Presentation

Better Risk Management – CPD Event

Join the ACAMS Ireland Chapter to hear experts from Kharon and PwC discuss risk management via Customer Due Diligence, with a focus on the European Supervisory Authority’s Risk Factors Guidelines and a deep dive into sanctions screening systems management.


18:30 Arrival and Registration
19:00 Welcome and Presentations
19:40 Q & A
19:55 Closing Remarks
20:00 Networking Event – Drinks and Canapés


  • Chris Gallagher, Director, PwC Ireland
  • Rob Duncan, Account Director, Kharon

Please submit any questions you have for the panellists in advance of the event:

Thanks in advance to Kharon and Citi, our hosts and sponsors for this event.

If you’re an ACAMS member, register with the ACAMS Ireland Chapter here – otherwise, contact us at the email above!
Note that this event is open to non-members.

KYC REMEDIATION and how to get it right


18:30 Arrival and Registration
19:00 Welcome and Presentations
19:45 Q & A
19:55 Closing Remarks
20:00 Networking Event – Drinks and Canapés


  • Elizabeth Henry, Head of Financial Crime Risk and MLRO, HSBC
  • Sam Meddick, Head of UK Regions JDX Consulting
  • Robert Henley, Director of Client Success, Fenergo

Please submit any questions you have for the panellists in advance of the event:



AFC Forum

The first ever ACAMS Ireland Chapter AFC Forum was launched this year on June 27, 2018.
The ACAMS Ireland Chapter Anti-Financial Crime Forum presents an opportunity for ACAMS Ireland members and friends from a variety of financial services providers to get together and exchange real-life examples of financial crime risks, knowledge share and bring awareness to many of the risk typologies impacting the financial sector.

The AFC Forum first event was kindly hosted by Paypal at their Ballycoolin offices and was well attended by nearly 40 specialised financial crime individuals from over 10 multi-national organisations.

Alessia Bräutigam as Chair of the AFC Forum committee welcomed all the attendees and introduced the Case Study speakers and opened up the discussion sessions;

Case Study 1 – “Terrorist Financing” Case Study
David Szuchman – VP, Global Financial Crime Compliance, PayPal

Case Study 2 – “Cybercrime” Case Study
Cianan Black – Global Investigations EMEA Team Lead, PayPal Zuzana Crawford – Global Investigations EMEA Team Lead, PayPal

There was an active and engaging discussion from all participants and industry types and much learned from all on both Case Studies reviewed. There were requests from attendees to consider further topics for future events such as;

  • Customer verification and authentication Risks · Law Enforcement engagement and case studies · Fraud risk typologies in relation to Terrorist Financing

Additionally, there was a request to share out the contact and informational resources provided by Europol. Europol forwards regular newsletters of the organisation’s activities and all details of how to subscribe and review past notices can be found at Europol.

We would like to give special thanks to our event sponsor, Lincoln Recruitment Specialists who kindly provided light refreshments before and after the event.

We held a pop quiz at the event and our lucky winner of the ACAMS Certificate Course Voucher was Ms. Pilch from Elavon, congratulations!
ACAMS CPD Certificate is available to all of those who attended, please follow up with ACAMS directly if you haven’t received your certificate yet.

GDPR for AML/CTF Professionals

ACAMS Dillon Eustace GDPR Briefing 2 May 2018

RapidRatings slides

AFC Forum slide

ACAMS Ireland Chapter hosted their second event of 2018 on 2 May 2018, at the Marker Hotel Grand Canal Square.

The focus of the evening was “GDPR for AML/CTF Professionals”, and the talks were led by Sana Khan Regional Counsel-Regulatory & Public Affairs from RapidRatings International Inc. and on behalf of the ACAMS Ireland Chapter Board.

Garrett O’Neill-Assistant Data Commissioner from the Irish Data Protection Commissioner’s Officer provided astute analysis of the Fourth AML Directive areas of overlap with the GDPR. Garrett highlighted the problems that could arise from a GDPR perspective during compliance efforts with the Fourth AML Directive requirements for collecting and processing personal data especially where GDPR requirements such as proportionality, data minimisation were not taken into consideration. Garrett suggested several practical methods that AML/CTF professionals could implement in order to balance both the requirements of the Fourth AML Directive with the GDPR.

Breeda Cunningham-Director Regulatory and Compliance Department from Dillon Eustace provided detailed analysis and practical advice regarding the supplier i.e. vendor management requirements of data controllers and data processors. She highlighted many ways by which organisations could demonstrate compliance to this requirement of the GDPR for example contractual agreements, to carrying out privacy and general background reviews of potential vendors before any exchange of information took place. Breeda focused many of her examples for the fund industry and the general financial sector to illustrate her points in a practical manner.

Brad Longenecker-Managing Director, People and Culture from RapidRatings International Inc., complemented the two previous speakers by highlighting how companies like RapidRatings would assist compliance, AML/CTF professionals with their third-party risk management. This could be achieved by utilising vendors to assist in carrying out a more holistic background checks and reviews of third parties. Brad highlighted that there was a direct connection with the financial health of a company deteriorating or in fact being in a low financial health position with the increase in the likelihood of compliance and regulatory breaches taking place. In GDPR terms this mean a breach of a supplier for example a data processor could lead to GDPR breaches of a data controller.
The event finished up with an active and discussion orientated Q&A session moderated by Sana Khan with Garrett O’Neill and Breeda Cunningham as panellists.
Also at the event

Alessia Bräutigam from PayPal formally made the announcement of the ACAMS Irish Chapter’s new initiative titled the “Anti-Financial Crime Forum” whereby AML/CTF professionals would be welcomed to discuss AML/CTF matters and share expertise and guidance on matters such as case studies and new trends etc.
The closing remarks included reference to ACAMS Europe forthcoming conference in Amsterdam, The Netherlands on the 30th of May 2018.
Attendees were then invited to network over refreshments kindly provided by RapidRatings & Dillon Eustace.

Ireland, EU and International Approach to Sanctions Screening, Reporting and Penalties

Download Slides

ACAMS Ireland Chapter hosted their first event of 2018 on March 8, 2018, at the Dublin office of Matheson.

The focus of the evening was “Approach to Sanctions Screening, Reporting and Penalties”, and the talks were led by Joe Beashel, Head of Regulatory Risk and Compliance, Matheson.

David Hodgson – Head of Content Strategists, Dow Jones Risk & Compliance, provided an overview of Sanctions ownership research and the complexities of the various regimes, he provided valuable insights into performing research to determine ownership thresholds and completing this research in various languages.

Colm Dawson, Lawyer from Matheson, shared his experiences by providing extremely interesting case studies on three different industries of advising on legal to execute contracts.

The event finished up by a very active and interesting Q&A session moderated by Joe Beashel with David Hodgson and Colm Dawson as panelists.

Thanks again to all the attendees & to the sponsors.

AFC (Anti-Financial Crime) Compliance Careers Networking Event

Download Narrative
Download Presentation 1
Download Presentation 2
Download Presentation 3

  • Overview of AFC Compliance Career Roles
  • AFC Skills and Professional Qualifications
  • International Career Pathway Comparisons


  • Mark Bonham – Senior Compliance Program Manager – Airbnb Payments
  • Suzanne Feeney – Director Legal, Compliance & Financial Services – Robert Walters
  • Donna Bucci – ACAMS Ireland Manager

Solving Complex KYC Challenges

ACAMS Ireland Chapter hosted the year’s 3rd event on September 27, 2017, this time at the Dublin office of Stripe.

The focus of the evening was “Solving Complex KYC Challenges”, and the talks were led by Kevin Nolan, Financial Crime Officer and MLRO from Wells Fargo Bank International, on behalf of the ACAMS Ireland Chapter Board.

Claus Christensen, CEO of Know Your Customer, discussed the digital future of KYC and complex entity structures. Know Your Customer are experts in the use of electronic documents for verification, and shared the benefits of such. Claus described the downfalls of documentary evidence, including examples of a forged utility bill and a passport he procured for himself for just $30 on the deep web. Claus then described the challenges of identifying ultimate beneficial owners, especially when a company’s owners sit across several countries, and illustrated how there are often no ultimate owners with 25% or more stake in a given entity. He used examples of Know Your Customer (Ireland) Limited, Fenergo LP Limited, and our hosts, Stripe Payments Europe Limited.

Kate Hotten, EU Compliance Officer for Stripe, shared the behind-the-scenes know your customer and anti-money laundering controls for one of Stripe’s products, Stripe Atlas. The product allows users to incorporate a C-Corporation in the U.S. state of Delaware and establish a U.S. business bank account, among a larger suite of services for entrepreneurs. Stripe capitalizes on several product features to create a holistic view of the customer, and the conversation focused on how companies can similarly think about building their products to organically support their KYC needs.

Michael Cocoman, Regulatory Counsel for Stripe, discussed the evolution of marketplaces and how today’s online marketplaces operate, with examples such as Amazon, Kickstarter, and Shopify. He tied this into an overview of the Payments Services Directive and what will change with the upcoming PSD2, effective January 13, 2018. PSD2 will require a closer look at the movement of money between marketplace participants to ensure all parties are adequately protected from loss, and that the marketplace is not directly involved in the movement of money without holding the appropriate license. Michael touched on how banks can identify potential red flags of non-compliance with PSD2, in this context, and products that marketplaces can leverage to be compliant.

ACAMS Europe then introduced upcoming educational events, including the Anti-Financial Crime Symposium in Dublin on October 19, 2017.

Attendees were then invited to network over refreshments kindly provided by Know Your Customer.

Download Presentation

Reporting of Suspicious Activity in Ireland – A Practical Discussion

ACAMS Ireland Chapter had our second Chapter Educational and Networking Event on the May 17 February 2017, hosted by PWC in their amazing top floor meeting suite at Spencer Dock. The focus of discussion and our guest presenters was on “Reporting of Suspicious Activity in Ireland – Practical Discussion”.

Opening remarks by Sinead Ovenden, PWC welcomed the wide audience of attendees from both banking, funds, insurance and fintech compliance community. PWC having an extensive and embedded business service provided to companies in the AML and Financial Crime space having actively been involved in drafting discussions on existing AML guidelines and statutory instruments in Ireland. Sinead kindly introduced our esteemed panelists from Irish Law Enforcement, Revenue Commissioners and Banking community.

Detective Sergeant Clodagh White presented an overview of the historical STRs (suspicious transaction reports). Some 23.3k STRs were reported in 2016, increase 7% on prior year. An overview what to monitor for suspicious activity and related KYC risks on identifying A summary reporting requirements was provided summarising the need to focus in on the typologies and trends which have emerged. She also highlighted useful tips of what data to include when filing an STR and how the FIU reviews each submission and collaboration with Law Enforcement activities. Highlighting the emphasis for AML and Compliance professionals filing STRs the protective regime for the individuals filing the STR.

  • The big announcement to note is the launch by the FIU of Electronic Reporting of STRs (goAML) goes live for both individual and batch filing as of 29th May 2017.

Justin Delaney from the Suspicious Transaction Unit highlighted the approach and crucial work conducted by the Unit when reviewing STRs. Highlighting that in Ireland there is a requirement to file both an STR with the FIU as well as with Revenue Commissioners and since in operation over 192,000 STRs have been filed since 2003, with over 2,000 being used in current investigations. STRs are risk rated by the Revenue to priorities work and case typologies received. There spread of market submitting STRS over nearly 80% comes from traditional Banks, Credit Unions, with approximately remaining 5% from Funds and 14% coming Money Transfer Companies (Payments companies). Justin kindly summarised the typical trends they are seeing in reported STR and highlighted the cooperation between FIU and Law Enforcement on approach to live investigations.

  • It was noted that dual reporting of STRs is a formal requirement to both the FIU and Revenue Commissioners however that there is a project in place to consider how can both organisations’ systems could communicate and share information. Thus avoiding the need for a reporting FI in Ireland to file twice the same information. There is expected some progress on this in the next 12 months.

Kevin Nolan Financial Crime Officer & MLRO Wells Fargo Bank International UC was our last speaker providing some valuable insights from the FI side in respect of filing and reporting STRs in Ireland. Highlighting the principle based approach that compliance professionals need to adopt and operating in identifying suspicious activity related to money laundering and terrorist financing. Commenting on the timeliness requirements, how to ensure your management and teams are engaged and up to date with the approach and how valuable it is to engage within ACAMS community to support keeping up to speed with developments in approaches to fighting Financial Crime.

After the formal presentations there was a lively panel discussion moderated by Sinead Ovenden and active engagement and questions from the attendees. Opportunities to engage with individuals from the Irish FIU, Revenue Commissioners and Law Enforcement is really valuable and welcomed by many of the attendees.

ACAMS Ireland Chapter has now in excess of 400 individual attendees over the past two years helping to bring together an open network for compliance professionals working in the Financial Crime environment in Ireland to share and collaborate. If you haven’t yet registered with the Ireland Chapter please get in contact with us via the Webpage or directly with ACAMS. ACAMS globally is celebrating 15 years anniversary this year with a global membership of 48,000 financial crime professionals, nearly 30% increase on last year.
Items to note:

  • CAMS Qualification – the current 5th CAMS Handbook is being updated and so any of you sitting your CAMS on the current version need to complete this before June 30th. The next edition updates much of the content in relation to EU and Asian regulatory changes and case studies.
  • Watch out for;
    • Next Chapter event will be in September
    • ACAMS are to hold a full day Symposium in October

Download Presentation

AML/CTF Efforts and Forecasts for Ireland

ACAMS Ireland Chapter had our first Chapter Educational Event of 2017 on the 23rd of February 2017 where the AML/CTF landscape was discussed at the Grant Thornton Offices in Dublin.


  • Sheila Duignan, Partner, Financial Services, Grant Thornton, introduced the evening and the speakers.
  • Elaine Duignan, Barrister for the Legal & Policy Team with the Central Bank of Ireland gave a very informative presentation outlining the Central Banks position on AML and CTF. Elaine outlined the progress to date with the FATF Mutual Evaluation and the transposition of the 4th AML Directive. Elaine spoke about the risk based approach and its importance.
  • Kevin Nolan, Financial Crime Officer & MLRO, Wells Fargo Bank International UC presented on behalf of the ACAMS Ireland board. Kevin outlined the main events on the schedule for Ireland and EU focusing o the 4th AML directive and some of the key challenges for firms.
  • Vicki Williams – Risk and Compliance Manager, PerfectCard, joined Kevin and Elaine for a panel discussion. Helen Hegarty from the AML Division of the CBI also joined the panel. Sheila Duignan engaged the panel with some questions from the audience.
  • The audience were then invited to network with refreshments provided by Grant Thornton.
  • ACAMS Ireland Chapter would like to thank Grant Thornton for hosting what was for all a very enjoyable and informative evening. We would also like to thank all of the speakers and contributors.
  • Download Presentation

ACAMS Ireland Chapter Winter Networking Event 2016

ACAMS Ireland Chapter in partnership with DMS Governance held their Winter Networking Event on the 24th November 2016 marking  the closure of a very successful inaugural year.

The event brought together our members and sponsors allowing us to  thank them for their continued  support throughout the year.

We would very much like to thank DMS for sponsoring such a wonderful evening

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!

Download Event Presentation

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

Download Event Presentation

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

Download Event Presentation

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: 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

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, which incorporated Inform, Money Laundering Alert and

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, CAMS®
ACAMS® Ireland Chapter Co-Chair
Head of Financial Crime, Utmost Group Ireland

Therese is the current Head of Financial Crime within Utmost Group Ireland, with responsibility for Financial Crimes compliance for the group. She was previously the International AML/KYC Manager within J.P. Morgan’ Merchant Services business based in Dublin, Ireland. She has been working in the Financial Services industry for 12 years. She is a Certified Anti Money Laundering Specialist (CAMs), a qualified accountant and holds the Licentiate of Compliance Officers of Ireland designation (LCOI).


Elizabeth Henry

Elizabeth Henry, CAMS®
ACAMS® Ireland Chapter Co-Chair
Head of Compliance & MLRO, Revolut

Elizabeth has over 18 years’ experience in the banking and financial services sector with a focus on Compliance. Currently as Head of Compliance and MLRO for Revolut Ireland, she is responsible for building and implementing the Compliance programs across the EU.  Previously, as Head of AML, Sanctions and Anti-Bribery and Corruption (FCC) for HSBC Ireland, Elizabeth was responsible for implementing the Bank’s FCC strategies, policies and standards for HSBC.

Prior to joining HSBC, Elizabeth was Director of AML for Western Union Payment Services Ireland Ltd, with responsibility for the Agent Oversight 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.

Kevin Nolan, CAMS®
ACAMS® Ireland Chapter Secretary Global Head of Financial Crime & Sports Integrity
Flutter Group

Kevin is the Global Head of Financial Crime & Sports Integrity for the Flutter Group. Prior to Flutter, Kevin led the Financial Crimes Risk Management Function of Wells Fargo Bank International UC as Financial Crime Officer & MLRO. Kevin has previously held a variety of positions with regulated organisations and multinationals, such as Western Union Payment Services Ireland Limited, within the fields of AML/CFT & financial crime; regulatory compliance and Corporate Governance. Kevin is a founding board member of the ACAMS Ireland Chapter and CAMS qualified; a member of the International Compliance Association and a Licentiate of the Association of Compliance Officers in Ireland (ACOI) where he is a member of the MLRO Forum and Chair of the Financial Crime Working Group.

Kate Hotten

Kate Hotten, CAMS®
ACAMS® Ireland Communications Director
International Head of Financial Crimes, Stripe

Kate Hotten is the EU Compliance Officer for Stripe, responsible for regional AML and ABC compliance and advising on Atlas, Stripe’s company incorporation product. Prior to Stripe, Kate worked in London and San Francisco on anti-bribery and corruption and as part of Wells Fargo’s financial crimes think tank.

Kate is a Certified Anti-Money Laundering Specialist (CAMS) and received a Master of Science in Economics from University of California, Santa Cruz.

Gavin Healy

Gavin Healy, CAMS®
ACAMS® Ireland Chapter Board Member
Head of Risk & Compliance, Prepaid Financial Services

Gavin is currently the Head of Risk & Compliance for Prepaid Financial Services and is currently the company CRO and MLRO. Gavin has 14 years’ experience working in the financial services industry where he has held senior manager roles in retail banks, e-money institutions and online gambling companies. Gavin is a fellow member of ACAMS and has obtained his CAMS certification. He is also a Certified Financial Crime Prevention Practitioner through the Institute of Bankers.

Alessia Bräutigam

Alessia Bräutigam
ACAMS® Ireland Chapter Programming Director
Senior Compliance Trainer, PayPal

Alessia has over 10 years of experience in AML and Financial Crime. In her current role as Senior Training Specialist within PayPal, Alessia is responsible for the development and delivery of training content for Global Financial Crime across the different AML/CTF and Brand Risk management areas for a number of markets and jurisdictions.

Alessia holds an International AML Diploma (ICA) and has completed the ACAMS Counter-Terrorist financing course and the AML Risks in Gambling & Gaming certificate (ICA). She is currently on her last year at Arden University where she is studying to earn a BA (Hons.) in Criminal Justice.

Kaitlin H. Lemmo

Kaitlin H. Lemmo, CAMS®
ACAMS® Ireland Chapter Boar Member
AML Compliance Assurance Group Manager, Citibank Europe

Kaitlin Lemmo joined Citi as the regional manager for the AML Pre-Closure Testing function in 2017. Prior to joining Citi in Dublin, Kaitlin spent over 10 years with Protiviti Inc. in the AML Consulting practice.  With nearly 15 years financial crimes experience, Kaitlin has supported financial institutions in addressing a range of program challenges including consent order remediation, AML/Sanctions technology implementation, look-backs, and designing enterprise-wide risk scoring models.

Kaitlin holds a degree in Economic Crime Investigation from Utica College, as well as her law degree from Loyola University Chicago. Recently, she completed an Advanced Diploma in Corporate, White-Collar, and Regulatory Crime at King’s Inns law society in Dublin. Kaitlin continues to participate on industry panels, perform research into emerging risks, and provide curriculum-development support on financial-crimes related training.

Kate Hotten

Lisa Van Wanrooy, CAMS®
ACAMS® Ireland Chapter Board Member
Risk Manager, Citco Group Ltd.

Lisa Van Wanrooy is the Chief Risk Officer for the Dublin branch of Citco Bank Nederland N.V., having joined the organization in 2018 in a risk second line of defense role.  She has over 25 years of experience in international financial services in Canada, Bermuda and Ireland.     She gained industry knowledge throughout her career with positions held across investor services, hedge fund operations and business analysis prior to progressing into operational risk management in 2012.

Lisa has obtained her Certified Anti Money Laundering Specialist (CAMs) certification and earned the Professional Certificate in Compliance from the Institute of Banking, Ireland.  She also holds an International Diploma in Risk Management from the Institute of Risk Management (IRM).