Against the backdrop of the increasingly important role played by electronic money institutions and payment institutions in the financial system, and the growing reliance placed on those firms by consumers, the Central Bank sent a Dear CEO letter to the CEOs of Irish e-money institutions and payment institutions on 9 December 2021.
The letter summarises the Central Bank's supervisory expectations of those firms, and also requires them to comprehensively assess compliance with safeguarding requirements and authorisation conditions by 31 March 2022. The firm's board must confirm to the Central Bank by 31 March 2022 that the assessment has been carried out and concluded. If issues are identified during the assessment, a board-approved remediation plan must be put in place that ensures the timely resolution of any issues identified.
The latest briefing from our Financial Regulation: Investigations and Enforcement Group analyses the Central Bank's supervisory expectations in more detail. Those expectations focus on areas that are consistently at the top of the Central Bank's supervisory agenda: governance and risk management, conduct and culture, safeguarding customer funds, sustainable business models and financial resilience, operational resilience, anti-money laundering and counter terrorist financing, and orderly resolution/wind-up.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.