Financial Sanctions and Terrorist Financing - additional obligations

Monitoring

To ensure compliance with the CJA 2010 and prevent the financing of terrorism, it is necessary for credit and financial institutions to monitor their customers and transactions against both the EU and UN Sanctions Committees lists relating to terrorism. The lists are regularly updated and must be frequently checked to ensure that they are the latest ones available.

Financial Sanctions lists that relate to terrorism should be monitored to assist in preventing terrorist financing from occurring, including, but not limited to, the following:

• EU Financial Sanctions list
• United Nations Sanctions Committees lists

What to do if a customer is on a terrorist list

If a credit or financial institution has knowledge or a suspicion of terrorist financing, it must immediately send a suspicious transaction report (STR) to An Garda Síochána and the Revenue Commissioners.

In the event that a customer is matched to either the EU terrorist lists or UN terrorist lists, the credit or financial institutions should file an STR immediately with the Financial Intelligence Unit in the Garda Bureau of Fraud Investigation, make a report to the Central Bank, and not carry out any service or transaction in respect of the account until the report has been made. When the report is made, the Gardaí can then take steps and/or give directions to the credit or financial institution in respect of the account as appropriate under the Criminal Justice (Terrorist Offences) Act, 2005 (the "CJA 2005") and/or CJA 2010. Where a person or entity is also listed in an EU Council Regulation relating to terrorism, there is a legal obligation to immediately freeze that person or entity's account.

Further Information on Financial Sanctions and Countering the Financing of Terrorism

Please see further information on financial sanctions 

Related information and guidance on targeted financial sanctions and the prevention of terrorist financing can also be found at the following links:

• Anti-Money Laundering and Countering the Financing of Terrorism Guidelines for the Financial Sector
• Criminal Justice (Terrorist Offences) Act 2005
• Criminal Justice (Money Laundering and Terrorist Financing) Act 2010
• Criminal Justice Act 2013
• Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018
• European External Action Service
• UN Sanctions Committee
• FATF Guidance on Targeted Financial Sanctions
• FATF Guidance on Terrorist Financing