E-Services and Communications Credit Union Limited

Background E-Services is authorised as a regulated financial service provider and is registered as a credit union under the Credit Union Act, 1997. The principal activity of E-Services involves the provision of financial services to approximately 15,000 members countrywide. In September 2016, following a thematic review, the Central Bank made E-Services aware of deficiencies in its F&P due diligence practices and instructed it to rectify the issues identified. The Central Bank issued an RMP detailing the deficiencies identified, as well as the remedial actions required. In January 2017, EServices represented to the Central Bank that compliance with all F&P items in the RMP had been achieved. In June 2017, the Central Bank went onsite at E-Services to conduct a further investigation and to verify the accuracy of E-Services’ RMP representations. This inspection found that, contrary to the representation made by E-Services in response to the RMP that all F&P deficiencies had been rectified, deficiencies pertained, both in terms of the due diligence conducted, and in E-Services’ systems and controls to achieve compliance with its obligations. The Central Bank accepts that this misrepresentation was not intentional. The Central Bank acknowledges that E-Services has, since 2014, as part of a programme taken steps to improve compliance; including a review of compliance with the F&P regime. PRESCRIBED CONTRAVENTION The Central Bank’s investigation identified a contravention of Section 21 of the 2010 Act the details of which are set out below: 1. Due diligence deficiencies Credit unions are required to conduct thorough due diligence to ensure that employees performing CFs comply with the Standards.