Readers may recall that the anti-money laundering and counter terrorism financing, example red flag training material was issued in May 2022. It is a publication by a Joint Practice Group with the Irish accountancy bodies, GNECB and the Garda Financial Intelligence Unit (JPG).
Following user feedback since publication, the JPG has now issued an update of the training material.
The main updates are:
change to reflect that section 1079 Taxes Consolidation Act 1997 applies to both auditors and to tax advisers;
clarification on reporting obligations under sections 42 Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, section 19 Criminal Justice Act 2011 and section 59 of the Criminal Justice (Theft and Fraud Offences) Act 2001;
clarification on use of words speculation/professional scepticism and suspicion;
expansion of references to reporting requirements when there is failure to keep adequate accounting records (see Appendix 4 of updated document).
You can access the red flags updated document here.