May 10, 2019

Central Bank of Ireland identifies failings in regulated firm’s anti-money laundering and anti-terrorism financing programs, imposes €280,000 fine

On May 8, 2019, the Central Bank of Ireland reprimanded and fined Campbell O’Connor & Company, a private client stock brokerage firm headquartered in Dublin, for violating sections 54(1) and (2), 35(3), 54(6), and 40(4) of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 during the period between July 2010 and November 2016.  Following an investigation of Campbell O’Connor, the Central Bank determined that the firm failed:

  • to conduct adequate AML and anti-terrorism financing risk assessments;
  • to monitor customer transactions;
  • to adopt adequate policies and procedures for detecting and preventing money laundering and terrorism financing;
  • to train staff to identify suspicious transactions, and;
  • to ensure appropriate due diligence by third parties.

Campbell O’Connor admitted the violations.  According to the Central Bank, by August 2018, the firm had taken measures to rectify the deficiencies identified in the investigation.  In assessing the penalty, the Central Bank took into consideration the firm’s cooperation and early settlement, the deterrent impact of the penalty on Campbell O’Connor and other regulated entities, the gravity of the violations, and the six-year period during which the violations took place.  The €280,000 fine represents a 30% reduction of the amount deemed appropriate by the Central Bank, in accordance with the Early Discount Scheme set out in the Bank’s Outline of the Administrative Sanctions Procedure.