The Irish Tax Institute updated its Anti-Money Laundering and Counter Terrorist Financing Guidelines for Members (the Guidelines) to take into account legislation up to December 2019, including recent changes introduced by the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 (the Act) and regulations introduced in 2019.
The Act re-enforces a tax adviser’s obligation to know their client and their client's business, both at the beginning of the relationship and on an ongoing basis. Knowing your client should be an iterative process that is maintained and updated throughout the business relationship and is not a process that should only take place when a business relationship commences.
The Act introduces several changes that will apply to all designated persons, including Chartered Tax Advisers. These include key changes in the following areas
- Business Risk Assessments
- Customer Due Diligence
- Policies, Procedures and Enforcement
