The ACOI responded to the Central Banks’ recent consultation on the ‘Anti-Money Laundering and Countering the Financing of Terrorism for the Financial Sector’ Guidelines (‘AML Guidelines 2019’) via Consultation Paper 128(‘CP128’). ACOI welcomed the opportunity to comment on the AML Guidelines 2019, a very important regulatory document, which will shape the AML/CFT activities in the firms our members' work in and will be a key enabler of our members in their day-to-day role. This submission was drafted by the Financial Crime Compliance Working Group (‘FCCWG’) of the ACOI. The FCCWG’s aims include providing members of the ACOI with a forum for discussion and the sharing of views on Anti-money laundering /Countering the Financing of Terrorism / International Financial Sanctions / Anti-bribery and Corruption (referred to collectively as ‘financial crime’) issues. It also identifies issues which may impact on ACOI members in their day to day functions as Financial Crime Compliance Officers and seeks to support and empower through education.

As members are drawn from all financial services industries, and in line with the Central Bank's direction, the feedback, on behalf of all ACOI member's is industry-neutral. We look forward to the publication of the Final AML Guidelines.'

To download the response please click here