Schedule 2 Firms

Registration for Anti-Money Laundering/Countering the Financing of Terrorism Purposes

On 26 November 2018, Section 108A of the Criminal Justice (Money Laundering and Terrorist Financing), Act 2010 as amended, introduced for the first time a statutory requirement for certain firms to register for anti-money laundering/countering the financing of terrorism purposes with the Central Bank of Ireland ('Central Bank').

When Does the Obligation to Register Arise

If your firm offers any of the following services and it is not otherwise authorised or licenced to carry on business by the Central Bank, then it will need to register with the Central Bank as a 'Schedule 2 firm'.

Schedule 2 Activities

1. Lending including inter alia: consumer credit, credit agreements relating to immovable property, factoring, with or without recourse, financing of commercial transactions (including forfeiting).
2. Financial leasing.
3. Payment services as defined in Article 4(3) of Directive 2007/64/EC of the European Parliament and of the Council of 13 November 200714 on payment services in the internal market amending Directives 97/7/EC, 2002/65/EC, 2005/60/EC and 2006/48/EC and repealing Directive 97/5/EC.
4. Issuing and administering other means of payment (e.g. travellers' cheques and bankers' drafts) insofar as such activity is not covered by point 3.
5. Guarantees and commitments.
6. Trading for own account or for account of customers in any of the following:
   1. Money market instruments (cheques, bills, certificates of deposit, etc.);
   2. Foreign exchange;
   3. Financial futures and options;
   4. Exchange and interest-rate instruments; or
   5. Transferable securities.
7. Participation in securities issues and the provision of services relating to such issues.
8. Advice to undertakings on capital structure, industrial strategy and related questions and advice as well as services relating to mergers and the purchase of undertakings.
9. Money broking.
10. Portfolio management and advice.
11. Safekeeping and administration of securities.
12. Safe custody services.
13. Issuing electronic money.

Exemptions from the Obligation to Register

If your firm is carrying out Schedule 2 activities, the obligation to register does not occur if your firm falls into any of the following two exemptions:

1. If cumulatively:

1. Your firm only carries out Schedule 2 Activity 6 above; and
2. Your firm's customers (if any) are members of the same group as your firm.

or

2. If cumulatively:

1. Your firm's annual turnover is less than €70,000; and
2. The total of any single transaction, or serious of linked transactions in relation to your firm's Schedule 2 activities does not exceed €1,000; and
3. Your firm's Schedule 2 activities do not exceed 5% of your firm's total turnover; and
4. Your firm's Schedule 2 activities are directly related to and ancillary to your firm's main business activities; and
5. Your firm only provides Schedule 2 activities to customers of your main business activities rather than the public in general.

How to Register as a Schedule 2 Firm

Use the below Schedule 2 Registration for Anti-Money Laundering/Countering the Financing of Terrorism Purposes form if you require registration as a Schedule 2 firm with the Central Bank. The Schedule 2 Registration Guidance will assist firms in completing the registration form.  

Send your completed registration form by e-mail to the Central Bank at [email protected].

Post-Registration Changes

Use the below Schedule 2 Change of Registered Details for Anti-Money Laundering/Countering the Financing of Terrorism Purposes form if the Schedule 2 firm amends any of the following details:

• Change to principal contact details;
• Change in legal or trading name;
• Change of address;
• Offering additional Schedule 2 activities; or
• Discontinuing certain Schedule 2 activities (submit a deregistration form if you are discounting all Schedule 2 activities).

Send your completed change of details form by e-mail to the Central Bank at [email protected].

For other changes including:

• Change in ownership (Direct and/or Indirect); or
• Other material changes.

Please contact the Central Bank by e-mail at [email protected] outlining the request change.

How to Deregister as a Schedule 2 Firm

Use the below Deregistration for Anti-Money Laundering/Countering the Financing of Terrorism  Purposes form if the firm: 

• Discontinues all Schedule 2 activities; or
• Subsequently gets authorised or licenced by the Central Bank for another activity.