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    Author

    Peter Oakes is an experienced anti-financial crime, fintech and board director professional.

    He has served in senior roles at central banks (Ireland & Saudi Arabia) and financial regulators (UK and Australia).

    Peter is an experienced board director of regulated finserv & fintech firms and advisor to regtech firms.

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Cohort #1 of Central Bank of Ireland’s Innovation Sandbox Programme: ‘Combatting Financial Crime’

9/1/2025

 
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Seven participants of the Central Bank of Ireland’s Innovation Sandbox Programme on ‘Combatting Financial Crime’ are:


1) AMLYZE is building an AML/CFT information-sharing framework that will use structured taxonomies and synthetic data to simplify detecting and preventing fraudulent activities.
​

2) Expleo Group has developed an anti-SMS fraud solution which installs on mobile phones to combat SMS fraud.

3) Forward Emphasis and Pasabi’s joint innovation will develop and test a Motor Insurance Application Fraud Analytics solution, leveraging AI-driven behavioural analytics, machine learning, and pattern recognition to detect fraud in the pre-sales process.

4) Roseman Labs enables secure, GDPR-compliant collaboration and analysis on sensitive data for regulated industries.

5) Sedicii (hello Rob Leslie) and PTSB Sedicii has partnered with PTSB to create a secure and private collaboration using zero knowledge proofs to verify names and addresses, in real-time, as part of their customer KYC process, using ESB Networks as the authority for address data in Ireland in full compliance with GDPR and which involves no sharing of personal data.

6) TrustElevate.com offers a privacy-preserving solution for verifying parental responsibility and child age.

7) Vidos.Id is developing digital identity verification solutions to help financial institutions verify digital identity documents and wallet-based credentials.

There are many familiar names here and a couple we hadn't encountered at www.moneylaundering.ie and www.fintechireland.com. Since this all very serious hashtag#regtech, we better dust off the www.regtechireland.com website!

All the best to the cohort.
First posted here
Combatting Financial Crime Theme

The theme of the Innovation Sandbox Programme is:
“Combatting Financial Crime – Through the use of innovative technology, foster and develop innovative solutions that minimise fraud, enhance KYC/AML/CFT frameworks, and improve day-to-day transaction security for consumers.”

The programme will encourage collaboration across the ecosystem to support the fight against financial crime. Programme outputs will include inter alia the documentation and sharing of learnings in fraud prevention and detection. The programme also aims to facilitate the development of new ventures and new business models that solve challenges identified in this sandbox theme and facilitate the faster and safer deployment of substantially new technologies, products, or services.

The Sandbox Programme framework comprises:
  • A structured programme of workshops
    Each month participants will engage in workshops on specific topics relevant to the theme of Combatting Financial Crime. The topics will be relevant to participants and tailored to their needs and requirements as much as possible.


  • Ongoing bespoke engagement with dedicated Sandbox Relationship Managers
    Each participant will engage regularly with their dedicated Sandbox Relationship Manager, who will act as their point of contact to oversee and coordinate participation throughout the programme. The Sandbox Relationship Manager will also liaise with a broad range of Central Bank teams – from across the pillars of Consumer and Investor Protection, Financial Regulation, and Monetary and Financial Stability – to provide regulatory advice and support as required.


  • Access to Data Platform
    Each participant can avail of access to a Data Platform offering data sets and tools relevant to the theme of Combatting Financial Crime. This will allow participants to test and develop their innovation.
The methodology and delivery of this programme will be subject to continual assessment and impact review.
What is the Challenge?
  • Trust is one of the fundamental cornerstones of a well-functioning, resilient financial system. Financial crime erodes this trust for those who rely on its integrity.

  • The fight against financial crime diverts resources away from economically and socially productive uses, and can undermine a country's financial stability.

  • The pace of innovation and new technologies has meant companies are vulnerable to criminals as they introduce innovations.

  • Globally, scams drove over $1 trillion in financial losses in 2023, while losses from Authorised Push Payment scams was valued at €9.9 million in Ireland in 2022, according to FraudSmart.

  • Financial crime is not just an issue for the financial sector, but for other sectors too. One of the key factors in successfully reducing financial crime is for firms and wider partners to work collaboratively by sharing data and intelligence.
​What are the Problem Statements?
  1. Overall: What technological solutions can help to deliver positive outcomes for consumers and firms by supporting them in combatting financial crime and fraud?

  2. Collaboration: Can collaboration and information-sharing between and within the financial system, technology providers and other stakeholders enhance the effectiveness of anti-money laundering and counter terrorism financing efforts?

  3. Firm obligations: How can innovative technology, including AI, be deployed to support firms to effectively meet their regulatory obligations?

  4. Patterns: How can technology be better deployed to detect patterns or other indicators of consumer behaviour that may indicate financial crime is taking place?

  5. Consumer protection: How can efforts to combat financial crime ensure that the solutions do not comprise privacy, data, security or consumer protection?

  6. Regulatory adaptability: What are the impacts of the changing trends and emerging technologies in financial crime on the regulatory frameworks? To what extent do the current regulatory frameworks enable or hinder the use of technology to combat financial crime?
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Sharon Donnery Former Deputy Governor at Central Bank of Ireland joins ECB as its Representative to the Supervisory Board

2/1/2025

 
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Sharon Donnery joins the European Central Bank as its representative to the Supervisory Board.

Sharon joins the ECB from the Central Bank of Ireland, where she served as a Deputy Governor, leading a wide range of initiatives in financial regulation and monetary policy. With her extensive central banking and supervisory experience, including her role as Ireland’s representative to the Supervisory Board and a member of the European Systemic Risk Board’s General Board, Sharon brings invaluable insights and expertise to our work.

See also:
  1. Central Bank of Ireland Directors on the Move - Changes to Directorates & Supervisory Operating Model (1 January 2025)
  2. Sharon Donnery ECB Profile 
  3. ECB Linkedin Post
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Central Bank of Ireland Directors on the Move - Changes to Directorates & Supervisory Operating Model (1 January 2025)

1/1/2025

 
Linkedin Post:  
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​Central Bank of Ireland Directors on the Move

Three weeks ago our Peter Oakes posted the news that Mary-Elizabeth McMunn (formerly Director of Banking, Payments and Credit Unions) at the Central Bank of Ireland was appointed, effective 1 January 2025, as Deputy Governor Financial Regulation at the Central Bank.  This followed news that now former Deputy Governor, Sharon Donnery, had accepted appointment by the European Central Bank to be its representative of the Supervisory Board.

Over the past few weeks various bits and pieces of news about other moves within the Central Bank executive team has dripped into the media.  As at the start of January 2025 we now have official confirmation of those movements.  These are:
  • Colm Kincaid becomes Director of Enforcement. Colm was previously Director of Consumer Protection.
  • Seána Cunningham becomes Director of Insurance. Seána was previously Director of Enforcement & AML Supervision*
  • Gerry Cross, becomes Director of Capital Markets & Funds. Gerry was previously Director of Financial Regulation, Policy & Risk.
  • Domhnall Cullinan becomes Director of Banking & Payments. Domhnall was previously Director of Insurance.
  • Patricia Dunne becomes Director of Horizontal Supervision*. Patricia was previously Director of Securities & Markets Supervision.
  • Adrian Varley becomes Director of Supervisory Risk, Analytics & Data*.  Adrian was previously Director of Prudential Analysis & Inspections.
​
* See below for details of changes to Directorates

​Changes to Central Bank of Ireland Directorates 

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As part of its changes to its supervisory approach while keeping a risk-based supervisory model approach, the Central Bank of Ireland has  adopted a new operating structure to include seven directorates, which will report into the existing Deputy Governors for Financial Regulation and Consumer and Investor Protection:
​
  • the removal/disbanding of the standalone Consumer Protection Directorate. 
  • creating three directorates responsible for sectoral supervision; a Banking & Payments Directorate (Domnhall Cullinan), an Insurance Directorate (Seána Cunningham) and a Capital Markets & Funds Directorate (Gerry Cross). All three directorates will have integrated teams responsible for all elements of our mandate and supervising risks as they relate to the sector. The work of the disbanded Consumer Protection Directorate means that the Central Bank will now supervise for consumer protection and investor interests at a sectoral and an individual firm level.
  • creating a Horizontal Supervision Directorate (Patricia Dunne) to work in partnership with the sectoral supervisory teams on a system-wide and thematic basis.  This Directorate will provide specialist input on key cross-sectoral risks such as conduct, behaviour and culture, anti-money laundering and terrorist financing, financial resilience, operational resilience and technology risks.
  • creating will also be a Supervisory Risk, Analytics and Data Directorate.  This looks to be a re-working of the former Prudential Analysis & Inspections Directorate.  The Director (Adrian Varley) assumes responsibilities for the new directorate.
  • creating a Policy and International Directorate.  This looks to be a reworking of the former Financial Regulation - Policy & Risk Directorate).  The Director role is currently vacant (as at 1 January 2025).

New look and feel of the Central Bank of Ireland's Financial Regulation and Consumer & Investor Protection Deputy Governor Functions

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In addition to the points raised above arising from the changes to the operating structure at the Central Bank of Ireland, it is worth noting/amplifying that:
  • Consumer Protection and AML Supervision have not disappeared.  They have been embedded into relevant sectoral teams across the Central Bank of Ireland's functions.
  • while the name 'Credit Unions' is no longer shows in the name of the Banking & Payments Directorate, there is no change to its activities or prominence with the new operating model.
  • there is no identification about where the new Fitness and Probity Unit will sit within the Central Bank.  This new unit was announced on 19 December 2024 
  • Governance & Operational Resilience Resilience moves to the Horizontal Supervision Directorate from the former Prudential Analysis & Inspections Directorate
  • Supervisory Risk & Horizontal moves to the Horizontal Supervision Directorate from the former Financial Regulation - Policy & Risk Directorate.
  • 'Enforcement Investigations' is renamed 'Regulatory Investigations' and 'Enforcement Activity' is now replaced by Enforcement Market Abuse & Oversight.
  • dropping of word 'Supervision' from the names of the Banking & Payments and Insurance Directorates.
Sources / Further reading:
  1. Great to read the news that Mary-Elizabeth McMunn currently Director of Banking, Payments and Credit Unions at the Central Bank of Ireland has been appointed, effective 1 January 2025, as Deputy Governor Financial Regulation at the Central Bank (11 December 2024) - https://www.linkedin.com/posts/peteroakes_deputy-governor-financial-regulation-appointment-activity-7272670698152636417-LyRg?utm_source=share&utm_medium=member_desktop
  2. Deputy Governor Financial Regulation Appointment (11 December 2024) - https://www.centralbank.ie/news/article/deputy-governor-financial-regulation-appointment-press-release
  3. Transforming Regulation and Supervision - https://www.centralbank.ie/regulation/transforming-regulation-and-supervision
  4. Central Bank establishes dedicated Fitness and Probity Unit (19 December 2024) - https://complireg.com/blogs--insights/central-bank-of-ireland-establishes-dedicated-fitness-and-probity-unit
  5. Central Bank decision to disband consumer protection unit fuels fears customers will be weakened (7 September 2024) - https://www.independent.ie/business/personal-finance/central-bank-decision-to-disband-consumer-protection-unit-fuels-fears-customers-will-be-weakened/a964031703.html 
  6. Central Bank of Ireland: Firms will hear ‘one consistent voice’ following model change (18 November 2024) - https://www.businesspost.ie/news/central-bank-of-ireland-firms-will-hear-one-consistent-voice-following-model-change/
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