IOMFSA - Update on Arrangements for COVID-19

This update covers 4 key areas:

1. Staff of the Authority working from home
2. Home working and increased risk of cybercrime
3. AML/CFT FAQs about Covid 19
4. Framework for appropriate regulatory forbearance is being developed
 
1. Staff of the Authority working successfully from home

The transition of Authority staff to home working has been successful and the team are fully operational. As previously notified, we are grateful for your support in sending requests and post electronically in the first instance. This is helping to ensure we can fulfil our role without undue delays.

2. Home working and increased risk of Cybercrime

We are aware that regulated entities may be facing increased attention from cybercriminals. The National Cyber security Centre has issued some useful guidance on this and is good source of reference for cyber security matters more generally.

3. AML/CFT Frequently Asked Questions about Covid 19

The Authority has been receiving queries regarding COVID-19 and how this affects meeting customers / certification of documents. The AML/CFT team have prepared some frequently asked questions to help regulated entities and DNFPBs understand how the requirements may operate at this time.

We have not needed to introduce any new requirements around CDD, instead we have taken some key points from the AML/CFT Handbook, particularly around electronic verification of documents in one place which we hope will be helpful.

It is intended that the document will be updated over time to address any new questions which may have generic application.

4. Framework for appropriate regulatory forbearance is being developed

The Authority is conscious that firms will be experiencing operational issues as they transition to an environment in which many of their staff are working from home. 

1. We have already recognised that there may be difficulties in finalising audits in the normal timeframes and confirmed that we will not be treating such delays as breaches. Regulated entities have also raised some other audit related matters with us, and we will be providing further guidance as part of our regulatory forbearance work (see below).
2. The Authority is currently considering other regulatory requirements and the areas where it will be appropriate to consider regulatory forbearance at this difficult time. Once this review is concluded we will issue guidance for regulated entities to help them in complying with the requirements and understanding where deadlines and requirements have been adjusted
3. We expect regulated entities to continue to notify the Authority where they are experiencing difficulties in complying with the requirements. It should be noted that the Authority will not consider new individual rule modifications at this time.