Bray Credit Union Limited

BACKGROUND Bray Credit Union is a regulated financial service provider and is registered as a credit union under the Credit Union Act, 1997. The principal activity of Bray Credit Union involves the provision of financial services to 26,886 members. The Central Bank has responsibility for securing the compliance of credit and financial firms with the CJA 2010. The Central Bank’s Anti-Money Laundering Division identified these breaches during an onsite inspection of Bray Credit Union in 2015. Following this inspection, an investigation was conducted by the Central Bank’s Enforcement Division. PRESCRIBED CONTRAVENTIONS The Central Bank identified six breaches of the CJA 2010, occurring between 15 July 2010 and February 2016, namely: Policies and Procedures The CJA 2010 requires credit unions to adopt policies and procedures, in relation to their business to prevent and detect the commission of money laundering and terrorist financing. This is vital in the effort to prevent the use of credit unions for the purposes of money laundering and terrorist financing. Bray Credit Union failed to adopt adequate policies and procedures in relation to its business to prevent and detect the commission of money laundering and terrorist financing, particularly in the following areas: customer due diligence, transaction monitoring, suspicious transaction reporting, staff training and record keeping. Customer Due Diligence The CJA 2010 requires credit unions to identify and verify members both when they are taken on and when the credit union has concerns relating to documents previously obtained for the purposes of identifying and verifying members.