Campbell O'Connor & Company

BACKGROUND The Firm was established in 1960 and is currently authorised as an investment firm under Regulation 5(2) of the European Communities (Markets in Financial Instruments) Regulations 2017 (as amended) and provides stockbroking services to its customers. In November 2016, the Central Bank's Anti-Money Laundering Division conducted an on-site inspection of the Firm as part of its ongoing engagement with the investment firm sector. The inspection identified a number of concerns regarding the Firm's compliance with the CJA 2010. The Central Bank engaged with the Firm on remediating the issues of concern and commenced an enforcement investigation in May 2018. PRESCRIBED CONTRAVENTIONS The Central Bank's investigation identified five breaches of the CJA 2010, namely: Risk Assessment Contrary to Section 54(1) and (2) of the CJA 2010, the Firm failed to conduct any risk assessment of ML/TF risk for over three years following the enactment of the CJA 2010. The risk assessment conducted between November 2013 and November 2016 failed to consider a number of key risks. Specifically: o The Firm failed to carry out an adequate assessment of the customer and geographic risks facing its business. • The Firm failed to carry out any assessment of the risk of terrorist financing facing its business. A thorough risk assessment of a firm's customer profile, the type of services offered to those customers and the countries in which those customers reside or conduct business is integral to ensuring that firms adopt policies and procedures to mitigate all relevant ML/TF risks. 2.