Elite IT Experts Anti-Money Laundering Statement

Legal Context

The law in Ireland on anti-money laundering (AML) and the countering of the financing of terrorism (CFT) is governed by The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended by Part 2 of the Criminal Justice Act 2013 (“the Act”). The Act transposes European Union Law on AML and CFT (the Third Money Laundering Directive (2005/60/EC) and its Implementing Directive (2006/70/EC)) into Irish Law.

The law on AML and CFT reflects, both at the European and Irish level, the recommendations made by the Financial Action Task Force (“FATF”), which is a specialist international organization that concentrates on the international fight against money laundering and terrorist financing. Ireland has been a member of FATF since 1991.

The Central Bank of Ireland (the “Central Bank”) is the competent authority in Ireland for the monitoring and supervision of financial and credit institutions’ compliance with their obligations under the Act. The Central Bank is empowered to take measures that are reasonably necessary to ensure that credit and financial institutions comply with the provisions of the Act.

Key features of Policy

Elite It Experts AML Policy is designed to ensure that employees comply with the requirements and obligations set out in legislation, regulations, rules and Industry Guidance , including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.

The AML Policy sets out the minimum standards which must be complied with by all staff and includes The appointment of a Money Laundering Reporting Officer who has responsibility for oversight of the business compliance with relevant legislation, regulations, rules and industry guidance.

  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the Group.
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer procedures.
  • Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity.
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate.
  • The maintenance of appropriate records for the minimum prescribed periods.
  • Training and awareness for all relevant employees
  • The provision of appropriate management information and reporting to senior management of the compliance with the requirements
  • Sanctions Policy:

    Elite It Experts Sanctions Policy is designed to ensure that the all employees comply with applicable sanctions laws in every jurisdiction in which it operates.

    All employees receive training on the Sanctions Policy at least once a year, with more detailed and advanced training for those whose roles involve heightened sanctions risks. Failure to comply with the policy may give rise to disciplinary action, up to and including dismissal.

    Anti-Bribery & Anti-Corruption Policy: Barclays has a zero tolerance policy towards bribery and corruption. Elite It Experts recognizes that bribery and corruption have an adverse effect on communities wherever they occur. If endemic, they can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organized crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies. Elite It Experts is committed to applying high standards of honesty and integrity consistently across our operations and in all our business dealings.