Allied Irish Bank

BACKGROUND AIB is authorised to carry on banking business in Ireland as a credit institution under Section 9 of the Central Bank Act 1971. AIB acquired the Educational Building Society (‘EBS’) on 1 July 2011. 3 AIB is one of the largest banks in Ireland with 206 branches, 20 business centres, 71 EBS offices and approximately 2.6 million customers. Its principal activities consist of retail and commercial banking. The Central Bank has responsibility for monitoring and enforcing the compliance of credit and financial firms with the CJA 2010. During 2013, the Central Bank conducted a review of AIB’s compliance with the CJA 2010. This review identified a number of issues concerning suspected non-compliance with the CJA 2010. The Central Bank subsequently engaged with AIB on remediation of the issues identified and an investigation into suspected breaches of the CJA 2010 commenced. PRESCRIBED CONTRAVENTIONS The Central Bank’s investigation identified six breaches of the CJA 2010, namely: Reporting of Suspicious Transactions Effective detection and prevention of money laundering/terrorist financing (‘ML/TF’) depends on timely identification and reporting of suspicious transactions within the financial services sector. Delays in reporting suspicions to An Garda Síochána and the Revenue Commissioners have the potential to undermine the investigation of ML/TF offences. Under Section 54 of the CJA, firms are required to have policies and procedures which address their obligation to identify, investigate and report suspicious transactions as soon as practicable.