Dealers of High Value Goods
High Value Goods Dealers (HVGDs) are businesses involved in high value sales where they accept cash payments of €15,000 or more for goods. This can be in one transaction or a series of linked transactions. Examples of these businesses include antique dealers, boat and car sales, dealers in precious stones, jewellers, etc.
Trust or Company Service Provider
A Trust or Company Service Providers (TCSP) is any person whose business provides any of the following services:
a) forming companies or other bodies corporate
b) acting as a Director or Secretary of a company under an arrangement with a person other than the company
c) arranging for another person to act as a Director or Secretary of a company
d) acting, or arranging for a person to act as a partner of a partnership
e) providing a registered office, business address, correspondence or administrative address or other related services for a body corporate or partnership.
f) acting, or arranging for another person to act, as a trustee of a trust.
g) acting, or arranging for another person to act, as a nominee shareholder for a person other than a company whose securities are listed on a regulated market.
Private Members' Clubs
Persons directing Private Members' Clubs (PMCs) where gambling activites are carried on are described as ‘designated persons’ under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Under the Act a PMC is referred to as a ‘designated person’ must guard against their business being used for money laundering or terrorist financing purposes. PMCs must apply to the Anti-Money Laundering Compliance Unit to register for money laundering compliance purposes.
What you need to do:
• You must submit an application form for registration.
• You must identify and verify the identity of your customers.
Tax Advisers/external Accountants (i.e. book-keepers)
Although the majority of Tax Advisors and Accountants are regulated by their designated competent authority, under Section 25 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 a ‘designated person’ includes tax advisers/external Accountants i.e. persons who are not regulated by a designated competent authority providing the following services:
• Tax Advice
• Tax Returns
• Book-keeping
What you need to do:
• You must apply Customer Due Diligence (CDD) to all your clients.
• You must keep an anti-money laundering (AML) file containing information on money laundering e.g. policies, guides, correspondence, etc.
• If you consider a transaction by your client to be suspicious you must report it, using the Suspicious Transactions Report form, to An Garda Síochána and to the Revenue Commissioners.