RegSol Blog


Transaction Monitoring: Central Bank issues Bulletin

November 2020

The Central Bank of Ireland (CBI) has released a Bulletin to remind regulated entities they supervise that the Act specifies that a designated person must monitor customer transactions. The purpose of this is to identify transactions that may be suspicious in nature. The Central Bank expects that the intensity of monitoring should be in step with the complexity and scale of those transactions so that the risk of ML/TF is also factored in.

The Central Bank therefore expects to see connectivity between a designated person’s Business Wide Risk Assessment, CDD, transaction monitoring, and Suspicious Transaction processes. A designated person should have sufficient and up to date information on file obtained during the CDD process to determine whether transactional activity is suspicious.

Some of the key findings the Central Bank identified are:

  • No triggers for controls to reflect any new risks or potential new risks arising from the disruption caused to the financial system e.g. new threats that have become evident during the COVID-19 pandemic as detailed in FATF’s “COVID-19-related Money Laundering and Terrorist Financing” paper in May
  • Time delays in reviewing and assessing unusual activity resulting in delays in reporting suspicious transactions to the relevant authorities
  • The use of generic monitoring thresholds across varying product, service, or customer types which do not reflect the nuances of expected transaction patterns of those customer/product/service types

The Central Bank expects designated persons to review the Bulletin and update their controls as required. 

Click HERE to view the bulletin.



By Judy de Castro