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1. DUBLIN CORK BOSTON NEW YORK TOKYO

2. Understanding the New Anti-Money Laundering Requirements in Ireland www.dilloneustace.ie

3. Implementation of the 3rd Anti Money Laundering Directive • Key changes arising from new proposed legislation • Changes in the Financial Regulator’s role • Status of the Guidance Notes • Reporting requirements/New offences • Practical steps to consider • Q & A Understanding the New AML Requirements in Ireland www.dilloneustace.ie

4. Implementation of the 3rd Anti Money Laundering Directive 2005/60/EC • Heads of Bill Published 2008 • Criminal Justice (Money Laundering and Terrorist Financing) Bill 2009 • Published July 2009 • Second stage debated before Dail Eireann October 2009 • Final passage of the Bill through Dail Eireann February 2010 • Expected to enacted by mid March 2010. • When enacted various sections of Criminal Justice Act 1994 will be • repealed. Understanding the New AML Requirements in Ireland www.dilloneustace.ie

5. Key changes arising from new proposed legislation • Introduction of Risk Based Approach • Customer Due Diligence • Reliance on Third Parties • Training and Procedures • Record Keeping • Authorisation of Trust or Company Service Providers Understanding the New AML Requirements in Ireland www.dilloneustace.ie

6. Key changes arising from new proposed legislation • Introduction of Risk Based Approach • 3rd AML Directive – may determine the extent of the Customer Due Diligence measures on a risk sensitive basis depending on type of customer, business relationship, product or transaction. • Bill – shall obtain information reasonably warranted by the risk of money laundering or terrorist financing on the purpose and intended nature of a business relationship with a customer prior to the establishment of the relationship. Understanding the New AML Requirements in Ireland www.dilloneustace.ie

7. Key changes arising from new proposed legislation • Introduction of Risk Based Approach • Identify Money Laundering and Terrorist Financial Risks by looking at: • Customers • Products • Channels • Geographic Location • Categorise Risk • High • Medium • Low • Risk Categorisation determines level of Customer Due Diligence required. Understanding the New AML Requirements in Ireland www.dilloneustace.ie

8. Understanding the New AML Requirements in Ireland • Key changes arising from new proposed legislation • Customer Due Diligence (CDD) • When does it apply? • 3 levels of CDD • Requirement to identify Beneficial Owner www.dilloneustace.ie

9. Key changes arising from new proposed legislation • CDD – When does it apply? • prior to establishing a business relationship; • prior to carrying out occasional transactions which individually or as a series amount to €15,000 or more; • prior to carrying out a service where there are reasonable grounds to believe there is a real risk of money laundering or terrorist financing; • prior to carrying out a service where there are reasonable grounds to doubt the veracity or adequacy of existing customer identification information. Understanding the New AML Requirements in Ireland www.dilloneustace.ie

10. Practical steps to consider: • Gap analysis; • Client Risk Assessment – Risk based procedures; • Updating policies and procedures; • Training – including refresher training on a regular basis. Understanding the New AML Requirements in Ireland www.dilloneustace.ie

11. To view additional slides and for more information on this topic please contact:– • paula.kelleher@dilloneustace.ie • breeda.cunningham@dilloneustace.ie Follow Up www.dilloneustace.ie

12. 33 Sir John Rogerson’s Quay, Dublin 2, Ireland Telephone +353 1 66 700 22   Fax +353 1 66 700 42 paula.kelleher@dilloneustace.ie breeda.cunningham@dilloneustace.ie E-Mail: enquiries@dilloneustace.ie  Website: www.dilloneustace.ie Dublin Cork Boston New York Tokyo Contact www.dilloneustace.ie