The single sentence "PEPs can be on-boarded and the account allowed to transact prior to senior management approval or enhanced due diligence being complete" on page 13 says it all.

When one reads between the lines of vague, flowery writing in the Central Bank of Ireland's latest anti-money-laundering compliance assessment, one uncovers some staggering accusations about the non-compliance that the regulator has unearthed at the banks it supervises.

In its summary of findings, published last week, the regulator said that it had found the following at the banks under its charge (although, mercifully, no single bank was to blame for all of them).

• The risk assessments are incomplete and, indeed, not 'effective' in considering the inherent money laundering/terrorist financing risks that the bank in question faces, i.e. they are worthless.
• The risk assessments are very vague and not thorough.
• AML/TF reviews are not included in annual monitoring and internal audit plans.
• Deficiencies have been found in the 'on-boarding' process for politically-exposed persons (PEPs) in the areas of initial screening, "the timing of senior management approval" (a vague-sounding phrase that, shockingly, can only mean that business relationships with PEPs have been known to begin before the moment of sign-off) and the failure to sufficiently identify, verify and 'document' (write down information about) the customers' source of funds and source of wealth.
• The flouting of stated AML/TF and sanctions policies.  
• Inappropriate and patchy training given to board and committee members and no 'enhanced' training for staff in key AML/TF and sanctions-related jobs.
• Shortcomings in relation to the coverage and the timing of automated screening of customer databases for sanctions-related purposes.

Some of these failings - notably late approval for the 'onboarding' of PEPs - are quite egregious. Will there be a flurry of fines? Only time will tell.