The Costly Result of Non-Compliance

Western Union Payment Services Ireland Limited (WUPSIL) has been hit with a substantial financial penalty of €1,750,000 by the Central Bank.

In March this year, I set out the Central Bank’s Enforcement Priorities for 2015. This case involved three of the cross-sector enforcement priorities identified in that article – AML/CFT compliance, outsourcing functions and the need for robust systems and controls. It also marks a significant increase to penalties imposed previously by the Central Bank for non-adherence to AML/CFT requirements.

WUPSIL is a global market leader in the provision of money transfer services. The “high-risk nature of the Firm’s business and its global reach” were cited by the Central Bank as determining factors in imposing such a high penalty.

The Central Bank found that the firm’s method of monitoring the outsourcing of key AML/CFT compliance functions fell short of what is required by the Criminal Justice Act 2010.  WUPSIL operates through a wide network of agents. The Central Bank identified failures by the firm to ensure that their agents obtained and retained Customer Due Diligence documentation. Failures were identified in WUPSIL’s training on AML and CFT compliance. The firm was also reprimanded for the quantity (or rather lack of) and quality of Suspicious Transaction Reports given to An Garda Siochana.

It is not enough for your firm to demonstrate that it has systems and procedures in place to satisfy legislative requirements; you must be able to demonstrate actual compliance or face the full weight of the Central Bank’s Enforcement Division.

Contact Laura Daly or Ronan McGoldrick for assistance with your regulatory compliance needs.


This publication is for guidance purposes only. It does not constitute legal or professional advice. No liability is accepted by Ogier Leman for any action taken or not taken in reliance on the information set out in this publication. Professional or legal advice should be obtained before taking or refraining from any action as a result of the contents of this publication. Any and all information is subject to change.

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