MCNAMARA CORPORATE SERVICES LIMITED

Enforcement Summary:

1.     An administrative penalty in the amount of $20,000.00 was imposed on MCNAMARA CORPORATE SERVICES LIMITED for its contraventions of the Anti-Money Laundering Terrorist Financing Code of Practice, 2008 (the “AMLTF Code of Practice”):

• section 12 of AMLTF Code of Practice (Requirement to Carry Out Risk Assessment);
• section 19(2) of AMLTF Code of Practice (Requirements of Customer Due Dilligence); and 
• section 31(B) of AMLTF Code of Practice (Requirement of Testing of Business Relationships)

2.     A Warning Letter was issued to MCNAMARA CORPORATE SERVICES LIMITED for its contraventions listed below:

• section 11(3A) of the AMLTF Code of Practice (Requirement for Independent Audit Function);
• section 47(1) and section 48(2) of AMLTF Code of Practice (General Training Requirements);
• regulations 16(1) and (2) of the Anti-Money Laundering Regulations, 2008 (Requirements of Staff Training); and
• Section 27 of the Regulatory Code, 2009 (Requirements for Business Continuity Plans)