1. DUBLIN CORK BOSTON NEW YORK TOKYO

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

3. Understanding the New AML Requirements in Ireland www.dilloneustace.ie 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

4. Understanding the New AML Requirements in Ireland www.dilloneustace.ie 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 When enacted various sections of Criminal Justice Act 1994 will be repealed.

5. Understanding the New AML Requirements in Ireland www.dilloneustace.ie 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

6. Understanding the New AML Requirements in Ireland www.dilloneustace.ie Key changes arising from new proposed legislation Introduction of Risk Based Approach 3 rd 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.

7. Understanding the New AML Requirements in Ireland www.dilloneustace.ie 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.

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

9. Understanding the New AML Requirements in Ireland www.dilloneustace.ie 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.

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

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

12. Contact www.dilloneustace.ie 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