Factsheets

In 2022, the global economy was expected to recover following the chaos unleashed by the COVID-19 pandemic. However, in 2023, organisations across all sectors still face a myriad of challenges. One of the areas in which Grant Thornton has been able to assist our clients in driving efficiency is through assisting businesses in delivering a ‘Cost Optimisation’ model.

Following enactment of the Central Bank (Individual Accountability Framework) Act 2023 on 9 March 2023, the Central Bank of Ireland (“CBI”) has launched a three-month consultation on key aspects of the implementation of the Individual Accountability Framework (IAF), including the publication of draft regulations and guidance.

The Central Bank of Ireland has reminded firms of their obligations to align the governance and oversight of MGA arrangements with the outsourcing requirements set out in Solvency II for Critical or Important Functions or Activities.

As a result of recent amendments to the Criminal Justice (Money Laundering and Terrorism Financing) Act 2010 to 2021, Virtual Asset Service Providers (VASPs) are now “designated persons” and are required to comply with the relevant Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) obligations.

The Central Bank of Ireland (“CBI”) set out their findings and expectations for Payment and E-Money firms in its “Dear CEO” letter published January 20, 2023. Rather than issuance of specific additional or “new” expectations, it is a re-affirmation of the out regulatory expectations of authorised Payment and E-Money institutions already set out in the December 2021 letter in the same vein. A year on from that letter, it is clear that the CBI believes the industry has a lot more to do.

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The Central Bank of Ireland introduced pre-emptive recovery planning requirements in 2021 and all (re)insurance undertakings have been required to have a recovery plan in place since 31 March 2022. Following submission of the first set of recovery plans by High and Medium-High Impact firms, the Central Bank carried out a thematic review and the main observations were communicated to firms.

Incorporating change management into your strategy can enable an organisation to pivot from a prescribed strategy to an emergent strategy and increases the likelihood that you will achieve your strategic objectives.

In May 2022 the European Commission issued a public consultation to gather evidence for its review of the second EU Payment Services Directive (2015/2366), and to inform its continuing work on open finance. The consultation forms part of the Digital Finance Strategy and the Retail Payments Strategy which aims to conduct a comprehensive review of the application and impact of PSD2 to assess whether legislation remains fit for purpose.

Final guidelines on common procedures and methodologies for the supervisory review and evaluation process for investment firms, along with final draft Regulatory Technical Standards on Pillar 2 add-ons for investment firms are published.

The Central Bank of Ireland has announced that the countercyclical capital buffer (CCyB) rate on Irish exposures is to be maintained at 0.5 per cent.

The introduction of the Consumer Protection Act highlights the Central Bank’s continued focus on consumer protection, with the specific purpose of closing the consumer protection gap in respect of consumer-hire agreements, hire-purchase agreements, including personal contracts plans (PCPs), and other forms of indirect credit such as Buy Now, Pay Later.

Significant changes to the dynamic of the financial services sector in recent years have shifted the paradigms in how we work. The increased digitisation of the workforce, changes in business models, globalisation, and remote working capabilities have led to a new approach to the delivery of services.

The Central Bank of Ireland (‘CBI’) has recently issued its latest Anti-Money Laundering Bulletin, focussing on the Virtual Asset Service Provider (‘VASP’) sector. In this bulletin, the CBI has provided its observations on a number of significant and widespread deficiencies across authorisation applications received from VASPs where roughly 90% of all applications are not meeting the required standard.

In line with the EU’s ‘Financing Sustainable Growth’ Action Plan 2018, the European Commission adopted a number of delegated acts which will impact (re)insurance undertakings and insurance distributors. These changes will apply from 2 August 2022.

This is the first article from Grant Thornton in our series on the Central Bank of Ireland (Central Bank)’s recovery plan Requirements. This introductory article provides an overview of the key requirements of the legislation, the timelines involved and main topics included in your recovery plan.