2021

Ireland - Threat Assessment - 2021 Page 1 of 45 Republic of Ireland �

“They say the clouds are lower in Ireland - I say Ireland is closer to Heaven” Michael Vatis Section 1 - Executive Summary ...... Page 3

Section 2 - Country Information ...... Page 4

Section 3 - Country Ratings ...... Page 5

Section 4 - FCN Country Ratings ...... Page 7

Section 5 - Key Harms Summary ...... Page 9

Section 6 - Key Threats Summary & Threats in More Detail ...... Page 10

Section 7 - Sanctions & Embargoes ...... Page 23

Section 8 - Terrorism/Terrorism Finance ...... Page 24

Section 9 - Money Laundering ...... Page 26

Section 10 - Response ...... Page 29

Section 11 - Detailed FATF Results ...... Page 38

Section 12 - Remittance & Migration Data ...... Page 39

Appendix 1- Threat Types Risk Ratings ...... Page 40

Appendix 2 - Sources ...... Page 41

Endnotes ...... Page 42

This Global Threat Assessment for Ireland 2021 is produced and published by Financial Crime News and all rights are reserved in- cluding copyright by Metriqa Limited. This GTA should not be used for commercial purposes without obtaining frst a licence or ex- press permission from the publisher. The Author and contributors are John Cusack, Ursula M’Crystal, Hannah Cusack & Sophie Giles. Additional thanks go to the many experts that have reviewed and provided comments including from both public and private sectors in Ireland.

Ireland - Threat Assessment - 2021 Page 2 of 45 Index: Low incidence of 1.7/1000 and gov- Section 1 - Executive Summary � ernment response of “BB.” Grey Lists: Rep of Ireland (Ireland) is not listed Sanctions & Terrorism: No Sanctions against by the US as a Country of Primary Concern in the Country. Tier 1 (Higher Threat) PPI Index respect of ML & FC, and is not listed by FATF, rating with a controls score of 908/1,300. Ire- or the EU on their “Grey” lists. land is ranked 62/138, and scored “Low” at NRA: Ireland’s NRA was published in 2016, 2.845/10 in the Global Terrorism Index. and identifed criminal activities considered Tax Evasion: The tax gap for Ireland is esti- particularly generative of illicit proceeds, being mated at €6.5 billion, or 1.7% of GDP. drug traffcking, fnancial crime, tobacco smuggling, tax evasion, prostitution, fuel laun- Response & Resilience: Ireland’s MER was dering, theft and burglary, cybercrime, human published in 2017. Based on a simple scoring traffcking, bribery and corruption; and other model developed by FCN, Ireland is rated at illicit trade, such as counterfeiting and intellec- 75% for technical compliance, and 48% for ef- tual property theft. fectiveness. Taking key areas only, scores are 62% and 50% respectively. According to the Corruption: TI CPI - 2020 - ranked 20/179 with NRA, 3 sectors are considered “High” risk for an overall score of 72 out of 100, beating the ML (net risk), namely retail banking, money Western European average. remittance frms and bureaux de change. Ire- Organised Crime: According to the NRA, land has a fnancial information sharing part- there are an estimated 40 OCG!s in Ireland. nership, known as Ireland’s Joint Intelligence Group (JIG). The JIG is led by An Guarda Drug Traffcking: 3 in 10 people in Ireland re- Siochiana (“Guardai”), the Irish Police, with rep- port illicit drug use during their lifetime, up resentatives from the private sector. from 2 in 10 a decade earlier. Overall Ratings: Ireland is rated overall Fraud: The most prevalent frauds include “Moderate” Risk, scoring 58/100 for fnancial white-collar crime, social welfare fraud, invest- crime and money laundering by FCN. The ment frauds, mortgage fraud, VAT/MTIC fraud, trend is currently rated as “Neutral.” Threats are commercial fraud, phishing, inheritance scams, rated “Low to Moderate” at 62/100 & Re- invoice redirection fraud, payment card fraud, sponse at “Moderate” at 54/100. cheque fraud, & card-not-present fraud. Cy- bercrime has taken over from asset misappro- priation as the most prevalent economic crime. FCN Rating: “Moderate” Risk 58/100 Human Traffcking: US Traffcking in Persons: - Trend “Neutral” Tier 2 Country Watchlist (2020); Global Slavery

Ireland - Threat Assessment - 2021 Page 3 of 45 Section 2 - Country Information - �

People & Geography: Ireland, from “Ierne”, is the Celtic Tiger (1995-2007) saw rapid eco- Gaelic for "western isle.” The Greeks, called this nomic growth, which came to an abrupt end in remote land of the west “Iernis”, & the Romans 2008 with the fnancial crises, which had a ma- “Hibernia”. Ireland’s capital is in Dublin, & it’s jor impact on the Irish banking system. Pre- population distribution is weighted to the east Covid 19, the economy recovered, fuelled by of the island, with the largest concentration large and growing foreign direct investment, being in & around Dublin (1.2 million out of a especially from US multi-nationals. Exports of total of approx 5 million) and overall urbanisa- machinery and equipment, computers, chemi- tion at 64%, with 871,000 migrants1 (17.6%). cals, medical devices, pharmaceuticals, food- stuffs & animal products go to the US 27.1%, Recent History & Leadership: The modern UK 13.4%, Belgium 11%, Germany 8.1%, Irish state received independence from the UK Switzerland 5.1%, Netherlands 4.9%, & France in 1921 for 26 southern counties whilst six 4.3% (2017). Imports of data processing northern (Ulster) counties remained part of the equipment, other machinery & equipment, UK. Ireland joined the European Community in chemicals, petroleum and petroleum products, 1973, and the euro-zone currency union in textiles and clothing, come from UK 29%, US 1999. Following parliamentary elections in 18.9%, France 12.1%, Germany 9.6%, & February 2020, no party achieved suffcient Netherlands 4.1% (2017). support to form a government, though a coali- tion has now been established with Micheal Crime: While Ireland is considered a relatively Martin as prime minister. low crime country, and ranked 16th safest3 out of 128 countries, as an advanced economy, Northern Ireland (NI) and the “Troubles”: signifcant criminal proceeds are generated. Deep sectarian divides between the Catholic and Protestant populations and systemic dis- Finance: Ireland4 is an important regional and crimination in NI erupted into years of violence international fnancial centre, and is among the known as the "Troubles" that began in the IMF’s 29 systematically important fnancial cen- 1960s. The Governments of Ireland and the UK tres. It is home to over 400 international fnan- brokered the Good Friday Agreement in cial services companies and growing, ranked Northern Ireland in 1998, that has led to peace as the 4th largest exporter of fnancial services and an end to terrorism, though dissident in the EU. The 5 largest Banks (out of 64 li- groups from the Irish Republic Army remain, censed by the CBI) serve Ireland, with more some involved in criminality. than 90% of domestic accounts, loans and mortgages are Bank of Ireland, Allied Irish Economy & Trade: Ireland2 is the 32nd largest Bank, Ulster Bank, Permanent TSB and Citibank economy in the world (10/27 in EU), with a Ireland. In Ireland5 95% of people (over 15) GDP of US$383 billion (2018), and govern- have bank accounts, 51% have a credit card, ment revenues of €101 billion. The Irish econ- with internet users making payments online at omy is dominated by services at 60%, followed 69%. Remittances inbound in 2017 were ap- by industry at 39% and agriculture at 2.6%, al- prox US$578 million (0.2% of GDP) according though employment levels are 84%, 11% and to the World Bank6. See Section 12 below for 5% respectively. The economic boom years of more details.

Ireland - Threat Assessment - 2021 Page 4 of 45 Section 3 - Country Dashboard - �

Information from leading sources produce 50 plus ratings for Ireland, covering both threats and responses in fghting fnancial crime, sanctions, proliferation fnance, terrorism & terrorism fnance.

No. Threats Ireland � ! No. Responses Ireland �

1 1 GDP - Economic Size * US$389 billion - 2018 (0.54% Global GDP) OECD - Global Forum * Compliant (C - 2017) GDP per Capita Medium Sized Advanced Economy on Transparency & Exchange Info for Tax Purposes (C for all 10 Categories) US$78,660 GDP per Capita (2018) (5/181)

2 World Economic Forum * 87.2 / 100 (73.2, 98.9,98.6, 78.1) 2 Global Slavery Index * 57.7 BB Security (OC, Terrorism, Homicides, 25th out of 141 Country Response Rating (ratings from AAA, AA, A, BBB etc - equal 23rd out Policing) of 162

3 World Economic Forum * 73.2 3 US Dept of State * Tier 2 Watchlist Organised Crime (34/141 - Trend - worsening) Traffcking in Persons

4 Numbeo Crime Survey 2020 54.43/100 4 Institute for Science & Security * 908/ 1300 57th/129 (1 being the highest) Proliferation Index - PPI * - Controls Good Controls score

5 US Institute for Health Metrics and 44,458 - 1.05% (2017) 5 International Telecommunication Union 0.784/1.0 - 1 being the best Evaluation - 2018 Global Cybersecurity Index 2018 (38/175) Illegal Drug Dependency / Disorders * Number/Share

6 Transparency International (TI) Corruption 72 / 100 6 World Bank Regulatory Quality * 1.6 (-2.5 to +2.5) Perceptions Index* (20/179) from WB Global Governance Indicators 15th/193 (1 being the best)

7 TRACE 22/100 7 TI - Exporting Corruption * Red Rated Bribery Risk Matrix Ranked 21st out of 200 Enforcement of the OECD Anti-Bribery “Limited or No Enforcement” Convention

8 Institute for Science & Security * Tier 1 8 Freedom House 97/100 Proliferation Index - PPI * - Threat Level Highest Threat Level Freedom Index “free”

9 9 Heritage Foundation 81.4/100 US Dept of State Not Listed INCSR Vol I & Vol II * Economic Freedom Index “Free” 5th out of 178 (2021)

10 US Dept of State Not Included 10 Basel AML Index 4.46/10 Country Reports on Terrorism * 2019 (106/141 - 1 being the worst)

11 Global Slavery Index 1.7/1,000 11 FIU Egmont Member/ Interpol / Europol Yes Egmont, Interpol & Europol GSI Incidence * Incidence of human traffcking Member

12 Global Slavery Index 8,000 12 Asset Confscations * Estimated below 1% No of estimated Modern Day Slaves Estimated numbers of modern day slaves over 1% of Proceeds

13 US Dept of Labor Not included 13 Country National Risk Assessment * Yes 2016 Child Labour

14 Institute for Economics & Peace “Low” Impact 14 Financial Information Sharing Partnership Yes Global Terrorism Index * 2.845 Irish Joint Intelligence Group

15 IOM Migration 871,000 Migrants 15 Yale Centre for Environmental Law & Policy 78.77/100 E - Emigration / I - Immigration (17.6% - 2020) Environment Performance Index (9/180 - 1 is the best)

16 Global Initiative Against Org Crime 1.85/5 16 Government Spending on Law & Order * 0.9% of 2018 GDP IUU Fishing Index * 10th best out of 151 Eurostat 2018 (0.5 Police, 0.2 Law Courts, 0.1 Prisons, 0.1 Other)

17 European Union No 17 Know Your Country 75.42/100 Listing of Countries for Illegal Fishing * Country Money Laundering Index (63/245 - 1 being the best)

18 US DoS - Wildlife Traffcking * Not Included 18 European Union * N/A Focus / Countries of Concern Third Country Grey List EU Countries are not eligible for this list

19 EUIPO & OECD Counterfeit Goods * 0.079% 19 FATF Standards 75% Propensity of Exports 40 Recommendations*

20 UNODC Incidence - 1,372/100,000 20 FATF Standards 48% Thefts per 100,000 people - 2017 * (Ranked 17/74 Countries) 11 IO"s on Effectiveness*

21 EU List NA 21 FATF Standards 62% None Co operative Jurisdictions for Tax Core 10 Recommendations * purposes

22 Global Financial Integrity Ireland is an Advanced Economy 22 FATF Standards 50% Illicit Financial Flows* Core 4 IO"s on Effectiveness *

23 Fund For Peace 19.90/120 23 FATF Counter - Measures No Fragile States Index (166/176 - 1 is the most fragile) Strategic Defciencies List *

* Indicates the information is included in the FCN Country Index

Ireland - Threat Assessment - 2021 Page 5 of 45 Section 3 Continued - Threats & Responses Rating Scorecard

The Country Dashboard RAG ratings are established based on the FCN Threats and Responses Rat- ing Scorecard set out below.

Threats Responses

No Higher Moderate Lower No Lower Moderate Higher

1 >US0.5 trillion >US$100 billion - 0.5 trillion

2 <50 >50 - <75 >75 2 “CC” “C” “D” “CCC” “AAA” “AA” “A” “BBB” “BB” “B”

3 <50 >50 - <75 >75 3 Tier 3 Tier 2 & T2 Watchlist Tier 1

4 >60 >40 - 60 <40 4 T3 <360 Controls / 1,300 T3 >360-425 Controls /1,300 T3 >426 Controls / 1,300 T2 <426 Controls /1,300 T2 >426-650 Controls /1,300 T2 >650 Controls /1,300 T1 Country <650/1,300 T1 650-975/1,300 T1 >975/1,300

5 >1% >0.75% - 1% <0.75% 5 <0.33 >0.33- 0.66 >0.66

6 <40 40 - 59 60 - 100 6 <0 - -2.5 0-1 >1 -2.5

7 >55 38 - 55 <38 7 Little of No Enforcement Limited/Moderate Enforcement Active Emforcement

8 Tier 1 Tier 2 Tier 3 8 <40 Between 40 - 70 >70

9 Included N/A Not Included 9 O - 59.9 Mostly Unfree/ 60 - 69.9 Moderately Free 70 - 100 MostlyFree/Free Repressed

10 Included N/A Not Included 10 >7 6 - 7 <6

11 >5% >2% - 5% <2% 11 No N/A Yes

12 >1 million >50,000 - 1 million 1% - 5% of est criminal >5% of est criminal proceeds proceeds

13 >10% child labour (4-15 >5% - 10% child labour (4-15 <5% child labour (4-15 ages) 13 No Yes >3 Years Old Yes <3 Years Old ages) ages)

14 >4 -10 >2 -4/10 0-2/10 14 No N/A Yes

15 >US0.5 trillion >US$100 billion - 0.5 trillion 60

16 >2.4 2 - 2.4 <2 16 < 1.5% of GDP >1.5% - 2% of GDP over 2% of GDP

17 Yes Red Card Yes Yellow Card No 17 <50 50-70 >70

18 Focus Countries N/A Not Included 18 Included N/A Not Included

19 >0.3 >0.2 - 0.3 <0.2 19 <50 using FCN Scoring Model Between 50 - 75 using FCN >75 using FCN Scoring Model Scoring Model

20 >1,500 >783 - 1,500 <783 20 <50 using FCN Scoring Model Between 50 - 75 using FCN >75 using FCN Scoring Model Scoring Model

21 Listed Red Listed Amber Listed Green / Unlisted 21 <50 using FCN Scoring Model Between 50 - 75 using FCN >75 using FCN Scoring Model Scoring Model

22 Above 20% of Trade Between 10 - 20% of Trade Below 10% of Trade 22 <50 using FCN Scoring Model Between 50 - 75 using FCN >75 using FCN Scoring Model (with 36 Advanced Econom- (with 36 Advanced Econom- (with 36 Advanced Economies) OR Scoring Model ies) OR ies) OR 1 of 36 Advanced Economies 1 of 36 Advanced Economies 1 of 36 Advanced Economies

23 >80 - 120 >60 - 80 <60 23 No N/A Yes

* Indicates the information is included in the FCN Country Index

FCN Scoring Model

Risk Score Risk Rating Risk Score Risk Rating Risk Score Risk Rating Risk Score Risk Rating Risk Score Risk Rating

High Moderate Moderate Threat Low Moderate High Threat 20 - 39 Threat Moderate Re- Threat Low Threat 1 - 19 Low Response Low Moderate 40 - 59 sponse 60 - 79 Moderate High 80 - 100 High Response High Risk Response Moderate Risk Response Low Risk Moderate High Risk Low Moderate Risk

Ireland - Threat Assessment - 2021 Page 6 of 45 #Section 4 - Financial Crime News (FCN) Country Ratings - �

From all the available information collected and results summarised in Section 3 above, up to 29 ratings have been selected, covering a broad base of threats and responses in fghting fnancial crime, sanctions, proliferation fnance and terrorism & terrorism fnance. The results make up the FCN Country Risk Rating Model.

FCN Individual Ratings - Rep of Ireland � !

FCN Final Ratings - Rep of Ireland � !

Financial Crime News 62/ 100 Financial Crime News 58/100 Threat Rating “Low - Moderate” Threat Risk Rating “Moderate” Risk

Financial Crime News 54/100 Trend Neutral Response Rating “Moderate” Response

For more details on the scoring model for FCN Ratings contact the Editor FCN directly for access to the Methodology

Ireland - Threat Assessment - 2021 Page 7 of 45 Ireland - Threat Assessment - 2021 Page 8 of 45 Section 5 - Key Harms Summary - �

The harms that result from the realised threats drugs were cannabis at 13.8%, MDMA at faced in Ireland from crime, ML, proliferation 4.4% and cocaine at 2.9%, with an estimated fnance & terrorism are substantial (See Section number of high risk opioid users of approx- 6 for details), including: imately 19,000.

• Murder rates in Ireland for 2017 were 0.9 per • According to the US Institute for Health Met- 100,000 people, with Ireland ranked 75/97 rics and Evaluation, illegal drug use depen- countries, dency / disorders affected 44,458 people in Ireland and 1.05% in 2017. • Kidnap rates were 45 per 100,000 people, and ranked 33/79 countries • 410 deaths in 2017 as a result of medical causes or trauma among people who used • Theft rates for 2017 were 1,372 per 100,000 drugs. people • Ireland has a low incidence of human traffck- • Robbery rates were 45 per 100,000 people. ing, with 1.7 in 1,000, estimating victims at • There were over 67,312 Thefts, 16,751 Bur- approximately 8,000. GSI also gives Ireland a glaries & 2,419 Robberies reported in 2019 good government response of “BB”, though amounting to almost 38% of all recorded of- US has put Ireland on its TIP Tier 2 Watchlist. fences. • Fraud, deception and related offences ac- • There were approx 7,800 vehicles stolen in counted for over 2% of all recorded offences 2014, albeit 68% of those were subsequently in 2015. Increasingly, the tools and tech- recovered. niques of choice to carry out frauds are through cyber tools and techniques. • Drug use in Ireland is increasing with 3 in 10 individuals reporting illicit drug use during • Estimated losses in tax revenues, amount to their lifetime in the 2014-15 period. This up €6.5 billion (US$7.2 billion) for 2014, with from 2 in 10 a decade earlier. estimates for VAT/MTIC fraud at €122 - €215 million7 (US$135 - US$239 million), estimat- • A drug survey for Ireland, also in 2014-15, ed losses from tobacco smuggling, generat- suggests that cannabis remains the most ing losses of €110 million, (US$122 million) commonly used illicit drug, followed by which is 2.5 times larger than the amount the MDMA/ecstasy and cocaine. Irish Government spends (€2.6 billion) on the • Illicit drug use was found to be more com- entire Irish Justice system (2018). mon among males and younger age groups. In young adults (15-34), penetration rates for

Ireland - Threat Assessment - 2021 Page 9 of 45 Section 6 - Key Threats Summary - �

The NRA published in 20168 identifed those are estimated at US$5.8 trillion12, or 6.7% of criminal activities considered particularly gen- global GDP based on a bottom up assessment erative of illicit proceeds, which were: of criminal markets, (including 3% of GDP for fraud) for 2018. In all fraud could be around • drug traffcking, 43% of criminal proceeds, with estimates of • fnancial crime, goods piracy around 34%, drug traffcking around 10%, theft around 5%, green crimes up • tobacco smuggling, to 4%, human traffcking around 3%, & smug- • tax evasion, gling around 1.5%. It is also estimated that these crimes are carried out by using cyber • prostitution, techniques, which is estimated to be poten-

• fuel laundering, tially up to 27% of proceeds.

• theft and burglary, A much earlier study from the UNODC pub- lished in 2011, which concluded core fnancial • cybercrime, crime (excluding fraud) estimated criminal

• human traffcking, proceeds at US$2.1 trillion or 2.5% of Global GDP. These studies if applied to Ireland would • bribery and corruption & generate a range of US$9.6 billion to US$25.6 billion, or a middle estimate of US$14.1 billion • other illicit trade, such as counterfeiting for core criminal proceeds (excluding fraud). and intellectual property theft.

Taking the US$14.1 billion fgure, proceeds Amounts identifed and set out in Section 6 available for laundering can be estimated at include estimates for the amount laundered in US$10.1 billion, and organised crime pro- Ireland by OCG’s annually at roughly 1.1% of ceeds are estimated at US$6.5 billion. Taking GDP, or more than €1.7 billion9 (US$2 billion), the most conservative approach with US$9.6 estimated tax evasion at €6.5billion10 (US$7.2 billion as proceeds, monies available for laun- billion) for 2014, with estimates for VAT/MTIC dering are US$7.3 billion, and organised crime fraud at €122 - €215 million11 (US$135 - proceeds are estimated at US$4.4 billion, US$239 million), estimated losses from to- which are higher than those estimates general- bacco smuggling, generating losses of €110 ly accepted for Ireland. million, (US$122 million),

Nevertheless, based on estimates from FCN’ GTA 2019, global proceeds of criminal activity

Ireland - Threat Assessment - 2021 Page 10 of 45 Section 6 - Key Threats in More Detail - �

In this Section 6, the most important criminal (CBI). The primary sources of funds laundered markets, are assessed and summarised based in Ireland are cigarette smuggling, drug traf- on available sources. fcking, diversion of subsidised fuel, domestic tax violations, prostitution, and welfare fraud. 6.1 National Risk Assessment (NRA): The Irish authorities estimate up to 80 percent of NRA published in 201613 identifed those crim- suspicious transaction reports (STRs) that can inal activities considered particularly genera- be linked to predicate crimes involve funds de- tive of illicit proceeds, which were drug traffck- rived from domestic tax violations and social ing, fnancial crime, tobacco smuggling, tax welfare fraud. While money laundering occurs evasion, prostitution, fuel laundering, theft and via fnancial institutions, illicit funds also are burglary, cybercrime, human traffcking, laundered through schemes involving remit- bribery and corruption and other illicit trade, tance companies, lawyers, accountants, used such as counterfeiting and intellectual proper- car dealerships, the purchase of high-value ty theft. goods for cash, transferring funds from over- For more details on these illicit proceeds see seas through Irish credit institutions, fltering the remaining sub sections of this Section 6. funds via complex company structures, and by basing foreign or domestic real property sales 6.2 US INCSR: Ireland is not listed as one of in Ireland. A number of cash seizures have oc- 80 Countries categorised by the US as a Coun- curred at Dublin International Airport. Customs try of Primary Concern in respect of money authorities have intercepted cash being smug- laundering and fnancial crimes in 201914. gled out of Ireland, likely proceeds from drug traffcking. According to Irish authorities, cur- rency intercepted on outbound passengers also may be intended for the purchase of drugs and/or cigarettes for smuggling back to Ire- land.”

6.3 WEF: According to The World Economic Ireland was listed in 2016, with the report stat- Forums Global Competitiveness Index 201915 ing that “Ireland continues to be a signifcant under Pillar 1 Institutions, Ireland’s rating for European fnancial hub, with a number of in- “Security” is 87.2/100 ranked 25th best out of ternational banks and fund administration frms 141. located in Dublin’s International Financial Ser- This overall score is made up of scores for or- vices Centre. These institutions are monitored ganised crime at 73.2 ranked 34/141, homi- and regulated by the Central Bank of Ireland cide at 98.6 (rate of 0.9/100,000 people) and Ireland - Threat Assessment - 2021 Page 11 of 45 ranked 29/141, terrorism incidence rate es, although concrete investigations are 98.9/100 ranked 94/141 & police service relia- scarce17. bility at 78.1/100 and ranked 27/141 (in all According to an EU report18 in 2014, it was es- cases higher scores are better). timated that corruption costs Europe €120 bil- lion (US$162 billion), or 1% of the EU’s GDP. A 2017 EU Survey19 provided the following sta- tistics:

• 5% (UK - 4% / EU - 5%) of those surveyed in Ireland stated that they had witnessed a case of corruption in the last 12 months; 6.4 Corruption: According to Transparency • 24% (UK 14% / EU - 25%) were personally International’s, (“TI”) Corruption Perceptions effected by corruption in their daily lives; Index 202016, Ireland was ranked 20/179 with an overall score of 72 out of 100, beating the • Giving or taking bribes was believed to be Western European average. most widespread in the following areas:

• Political Parties (Ireland - 53%, EU - 56%, UK - 44%)

• PEPs (Ireland - 47%, EU - 53%, UK - 42%)

• Police & Customs (Ireland - 34%, EU - 31%, UK - 21%) 72 out of 100 score, and ranked 20 out 179 countries for Perceptions of Corruption • Banks & FIs (Ireland - 51%, EU - 33%, UK - TI’s CPI 2020 29%)

Despite low perceived corruption levels, al- 6.5 Organised Crime: According to the NRA, most a third of businesses (2016) report that there are an estimated 40 Organised Criminal corruption has been an obstacle for the possi- Groups (OCGs) in Ireland, of which at least 9 bility to win a public tender in the past three have international links with OCGs in regions years; and according to around half of citizens, such as the Netherlands, Spain, West Africa the risks of corruption have increased because and the United Kingdom. “The presence in Ire- of the close ties between politicians and busi- land of foreign OCGs is evident in multi-juris- nesses. There are also some suggestions that dictional economic crime areas such as human cartels control certain sectors, such as bid traffcking, drugs smuggling and distribution, price rigging and corrupt evaluation process- frearms smuggling, tobacco smuggling, vehicle theft, and counterfeiting,” according to

Ireland - Threat Assessment - 2021 Page 12 of 45 the report. Moreover, the level of multi-jurisdic- Irish OCG’s of particular note, according to the tional OCG activity in Ireland “has increased in Irish Times23 reporting evidence aired in the recent years, both on a cross-border basis; with Irish courts in 2018, refer to crime gangs as OCGs in Northern Ireland, and internationally, controlling a vast international network of where increased collaboration has become drugs and arms smuggling, that have feuded evident.” with rival gangs, resulting in Ireland experienc- ing a surge in the number of OC-related mur- Varying estimates assess the amount ders and attempted murders, mostly related to laundered in Ireland by OCG’s annually at controlling the Irish drug market. roughly 1.1% of GDP, or more than €1.7 bil- lion20 (US$2 billion). According to the Guardai, the proportion of foreign nationals or ethnic crime gangs in- €1.7 billion laundered annually by organ- volved in organised crime in Ireland was rela- ised crime University of Trento Italy tively low, indicating that the vast majority of people from other countries living in Ireland Interpol in Ireland21 states that Ireland’s loca- were law abiding. Ethnic gangs are known to tion, makes “it a targeted source and transit most often target their own nationalities. For country for crime groups smuggling illicit mer- example, Vietnamese drugs gangs traffc Viet- chandise into or from European markets” and namese nationals to Europe and into Ireland, that “Ireland’s principal transnational crime and intimidate them to cultivate the drugs in challenges include drug traffcking, cybercrime, cannabis grow houses.24 Foreign nationals tar- and the threat from national and international geted by the Guardai recently, have included terrorism.” foreign gangs that work closely with Irish or- ganised crime gangs, as illustrated by the ar- According to a 2018 report which mapped the rests and convictions of a Lithuanian gunman risk of Serious and Organised Crime infltration and a Moroccan gangster in Ireland. Georgian in European Businesses22, “the roots of organ- nationals based in Ireland, and connected to a ised crime in Ireland have mostly developed in pan-European group of connected Georgians, conjunction with the expansion of the drug are another important target in Ireland. These market,” with, “the Irish context characterised individuals were involved in the large scale by a plurality of criminal actors: including well- production and distribution of false identity established (local) OCGs, loosely connected and travel documents, including passports, local networks, occasional criminal enterprises, national ID cards and driving licences, which groups linked with foreign OCGs (including helped a large number of foreign nationals to Italian $Ndrangheta or Russian-speaking circumvent immigration laws for the purpose OCGs), groups linked with former local para- of entering Ireland and the UK illegally. military groups.”

Ireland - Threat Assessment - 2021 Page 13 of 45 The 2020 OSAC25 report advises that the worth of drugs, 109 frearms, more than 3,400 Guardai “has focused resources primarily on rounds of ammunition and €11m in cash, from violence associated with organised criminal 2016 to end 201927. groups, particularly related to drug traffcking. Proceeds from drugs offences are generally Violence has resulted in the murder of multiple cash-based, with intelligence suggesting that individuals associated with criminal organisa- bulk cash transportation, third party launder- tions”. ing, high value goods dealers, cash-intensive According to The World Economic Forum, Ire- front businesses and gambling are some of the land has an organised crime score of 73.2/100 laundering methods commonly used by crimi- (higher scores are better) ranked 34/141 coun- nals associated with drug traffcking. However, tries. See above in Section 6.3. the emergence of online drug purchasing and the possible use of cryptocurrencies to fund 6.6 Drug Traffcking: In relation to illicit drugs, such purchases are thought to be increasing. Ireland is, according to the US Government26, “a transshipment point for & consumer of According to the European Monitoring Centre hashish from North Africa to the UK and for Drugs and Drug Addiction, drug use in Ire- Netherlands and of European-produced syn- land is increasing with 3 in 10 individuals re- thetic drugs; increasing consumption of South porting illicit drug use during their lifetime28 in American cocaine; minor transshipment point the 2014-15 period. This up from 2 in 10 a for heroin and cocaine destined for Western decade earlier. The most recent survey for Ire- Europe; despite recent legislation - narcotics- land, also in 2014-15, suggests that cannabis related money laundering - using bureaux de remains the most commonly used illicit drug, change, trusts, and shell companies involving followed by MDMA/ecstasy and cocaine. Illicit the offshore fnancial community - remains a drug use was found to be more common concern.” among males and younger age groups. In young adults (15-34), penetration rates for The NRA assesses that drug traffcking poses drugs were cannabis at 13.8%, MDMA at 4.4% the most signifcant ML threat to Ireland. Intel- and cocaine at 2.9%, with an estimated num- ligence suggests that while domestic OCGs ber of high risk opioid users of approximately are the main perpetrators of drug offences, 19,00029. they are closely linked with international OCGs, with Ireland vulnerable to use as an en- 3 in10 reporting illicit drug use during their try-point for illicit drugs into the EU (including lifetimes European Monitoring Centre for Drugs & Drug the UK), and as a conduit for onward transit to Addiction other EU markets. According to the US Institute for Health Metrics According to the Gardai’s Drugs and Organ- and Evaluation, illegal drug use dependency / ised Crime Bureau , they have seized €168m Ireland - Threat Assessment - 2021 Page 14 of 45 disorders affected 44,458 people in Ireland 6.8 Human Traffcking: Ireland was cate- and 1.05% in 201730. gorised as a Tier 2 country in the US Traffcking in Persons Report 201933, but has since been 6.7 Theft and Burglary: Theft and burglary downgraded to a Tier 2 Watchlist country in related offences are the most commonly the 2020 report. This is all the more concern- recorded offences in Ireland, with over 67,312 ing as Ireland was a Tier 1 rated country in the Thefts, 16,751 Burglaries & 2,419 Robberies 2016 & 2017 Reports. reported in 201931 amounting to almost 38% of all recorded offences.

Of particular concern, according to the NRA are metal theft and vehicle theft. It is known that foreign OCGs are involved in sophisticat- ed metal thefts affecting the transport, utility, recycling and communications sectors. Vehicle theft remains a signifcant source of proceeds 34 for OCGs, with approx 7,800 vehicles stolen in According to the 2020 report, the Irish gov- 2014, and 68% of those subsequently recov- ernment “did not demonstrate overall increas- ered. ing efforts compared to the previous reporting period. The government has not obtained a A signifcant proportion of vehicles are stolen traffcking conviction since the law was amend- to be subsequently dismantled into parts for ed in 2013, which weakened deterrence, con- sale or for exportation out of Ireland. An tributed to impunity for traffckers, and under- emerging trend is the theft of high end vehi- mined efforts to support victims to testify. The cles, for export to Eastern Europe or to Asia. government continued to have systematic def- ciencies in victim identifcation, referral, and Intelligence suggests that the proceeds of ve- assistance. The government continued to lack hicle theft are largely in cash and are laun- specialised accommodation and adequate ser- dered through businesses, such as HVGDs or vices for victims, and the amended working other cash intensive businesses, or used by scheme for sea fshers increased their vulnera- OCGs to fund further drug traffcking activities. bility to traffcking. Therefore Ireland was Plant and machinery theft is also a known downgraded to Tier 2 Watch List.” target area, and with construction activity in

Ireland rising again, it is likely to be considered The 2020 Report states that as “reported over a growth area for OCGs. the past fve years, human traffckers exploit domestic and foreign victims in Ireland, and According to UNODC32, theft rates for 2017 traffckers exploit victims from Ireland abroad. were 1,372 per 100,000 people and robbery Traffckers subject Irish children to sex traffck- rates were 45 per 100,000 people.

Ireland - Threat Assessment - 2021 Page 15 of 45 ing within the country. Foreign traffcking vic- and trusts37. Estimates for VAT/MTIC fraud is tims identifed in Ireland are from Africa, Asia, €122 - €215 million38 (US$135 - US$239 mil- Eastern Europe, and South America. Authorities lion). and media have reported an increase in sus- 6.10 Tobacco Smuggling: In 2015, tobacco pected victims from Nigeria, Romania, Indone- generated over €1 billion (US$1.11 billion) in sia, Brazil, and Pakistan. Traffckers exploit vic- excise duty in Ireland, with an estimated 11%39 tims of forced labor in domestic work, the of overall consumption in 2013, considered to restaurant industry, waste management, fsh- be from illicit sources, generating losses to Ire- ing, seasonal agriculture, and car washing ser- land’s Revenue of €110 million, (US$122 mil- vices. Vietnamese and Chinese individuals who lion). are convicted for cannabis cultivation often re- port indicators of forced labor, such as docu- Intelligence suggests that illicit tobacco prod- ment retention, restriction of movement, and ucts, including counterfeit products, entering non-payment of wages. Undocumented work- the Irish market originate primarily from East- ers in the fshing industry and domestic work- ern Europe and Asia. Illicit tobacco is often ers, particularly au pairs, are vulnerable to traf- transported in a manner similar to illicit drugs fcking. The government has reported the prob- via established international trade routes. Due lem of forced labor in the country is growing. to the nature of illicit tobacco sales, the pro- Women from Eastern Europe who are forced ceeds generated are largely in cash. Intelli- into marriage in Ireland are at risk for sex traf- gence suggests that bulk cash transportation, fcking and forced labor.” third party laundering, cash-intensive busi- nesses, money transmission businesses and According to the Global Slavery Index35, Ire- bureaux de change are common methods land has a low incidence of human traffcking, used by criminals to launder dirty money asso- with 1.7 in 1,000, estimating victims at approx- ciated with tobacco smuggling. imately 8,000, ranking Ireland 5th best in Eu- rope and Central Asia out of 50 countries as- 6.11 Fuel Laundering: Fuel laundering has sessed. GSI also gives Ireland a good govern- long been a major concern in Ireland, and was ment response of “BB.” highlighted in both the NRA and in the 2016 US INCSR. Even though in 2016 fuel launder- 6.9 Tax Evasion/Fraud: The tax gap for Ire- ing was considered relatively “negligible and land is estimated at €6.5billion36 (US$7.2 bil- close to being fully eliminated40”, further ac- lion) for 2014. In 2015, Ireland’s Revenue tions have been taken to make it much more raised €642.5 million (US$712 million) from diffcult for criminals to beneft from this crime. audit and compliance interventions, amount- ing to approximately 1.4% of the total collec- 6.12 Fraud: The NRA assessed that the most ted, with approx €60 million (US$66 million) prevalent frauds include white-collar crime, coming from investigations into offshore assets social welfare fraud, bogus investment frauds, Ireland - Threat Assessment - 2021 Page 16 of 45 mortgage fraud; VAT/MTIC fraud, commercial petrated by customers, 33% by hackers, and fraud, phishing, Inheritance scams, invoice re- 25% by organised crime. direction fraud, payment card fraud, cheque In March 2019, the Irish Central Statistics Offce fraud; and card-not-present fraud. Fraud, de- published its crime statistics for Q4 2018. ception and related offences accounted for There was a signifcant increase of 18.4% in over 2% of all recorded offences in 2015. In- recorded incidents of fraud, deception and creasingly, the tools and techniques of choice related incidents to the Garda for the year to carry out frauds are through cyber tools and 2018 compared to 201743. techniques. Another fraud typology that appears to be on The NRA further notes that the proceeds of the rise is identity fraud, where identifcation cybercrime usually take the form of electronic and verifcation documentation is produced, payments, “which are transferred through the for example to open new bank accounts. fnancial system, money remittance frms, and These accounts are used as mule or funnel ac- more recently using cryptocurrencies such as counts to receive the proceeds of fraudulent Bitcoin”, and references the use of so called transactions, and to redirect them - often “mule accounts to launder the proceeds of cy- quickly overseas - once they are received into bercrime in Ireland.” the account. The poor application of electronic According to PWC’s Economic Crime Survey identifcation and verifcation controls reduces for 201641”, the “full extent to which economic the ability to combat this activity. Mule ac- crime is plaguing Irish business is astonishing, count activity appears to be increasing especially when compared to our global coun- amongst high school & university students, terparts. Half of Irish companies report that who are actively targeted by mule herders, to they have been victims of fnancial crime.” Irish use their accounts to facilitate fraudulent activi- Businesses, have lost an average of €1.7 mil- ty. lion in 2016 up from €498,000 in 201442. 6.13 Other Reported Crimes: The numbers PWC Ireland observed that the most reported for reported crime for 2019 are on the move. technique is through cyber attacks or tech- According to the country’s Central Statistical niques and worryingly that, “the increase in Offce44, fnancial crime related offences are economic crime is Ireland is happening faster made up of Theft at 30.2%, Drugs Offences at than anywhere else in the world.” PWC believe 8.6%, Burglary at 7.5%, Organised Crime at that the incidence of cyber enabled crime in 7.4%, Fraud at 3.2% & Robbery 1.1%. Ireland may be double that of other business- es outside of Ireland. As far as external fraud Compared to 201645 higher reported incidents on businesses was concerned, 42% were per- in 2016 against 2029 were reported for Rob- bery, Drugs & Fraud, whilst Theft & Burglary

Ireland - Threat Assessment - 2021 Page 17 of 45 was lower. Based on (yet to be validated) Q1 property theft, including counterfeit products, 2020 statistics, the number of controlled drug which are imported into Ireland through estab- offences rose by 15.7% compared with the lished and legitimate trade routes, for example previous year. The number of Fraud, deception from China, including Hong Kong, India & and related offences recorded also increased Vietnam with consignments often disguised as by 14.9% incidents over the year. legitimate products to conceal their nature. The emergence and growth of online advertis- ing and online markets is increasing the avail- ability of illicit products in Ireland.

6.15 Emerging Threats: Cybercrime: Accord- ing to PWC48, 61% of Irish organisations expe- rienced cybercrime in 2018, up from 44% in 2016, which was almost double the rate in 2012. Law enforcement intelligence suggests that the proceeds of cybercrime are typically electronic payments which are transferred through the fnancial system, money remit- tance frms and, more recently, using cryp- tocurrencies such as Bitcoin. An emerging 46 According to UNODC homicide rates in Ire- trend is the use of cryptocurrencies, such as land for 2017 were 0.9 per 100,000 people, Bitcoin, to launder the proceeds of computer- with Ireland ranked 75/97 countries, and kid- enabled fnancial crime. nap rates were 45 per 100,000 people, and ranked 33/79 countries (with 1 being the high- According to the 2020 OSAC report, “Cyber- est). crime is a major concern, particularly with more than 700 US companies and many of the lead- According to The World Economic Forums ing technology frms locating their European 47 Global Competitiveness Index 2019 under headquarters in Ireland. The Irish government Pillar 1 Institutions, Ireland’s homicide rate is at has been taking proactive steps to address this at 98.6 (rate of 0.9/100,000 people) and growing threat, including approving a new Na- ranked 29/141 countries. tional Cyber Security Strategy. The Irish gov-

6.14 Emerging Threats: Other Crimes: Intel- ernment has yet to provide data on the number ligence suggests that domestic and foreign of reported cyber crimes”.

OCGs, opportunist criminals and individuals 6.16 Emerging Threats: Cross Border Crime: are involved in illicit trade. This includes of- The Republic of Ireland has one land border fences such as counterfeiting and intellectual with Northern Ireland (NI) as part of the UK,

Ireland - Threat Assessment - 2021 Page 18 of 45 though customs checkpoints were made re- both countries are committed to avoiding a dundant with the launch of the European sin- hard border, differences in duties and excise as gle market on January 1, 1993, which provided well as the location and seriousness of cus- for free movement of goods, services, people toms checks will determine the level of smug- and capital within the EU. Whilst import duties gle of goods for proft which will be hard to on goods were no longer applied, excise du- resist for criminal gangs. ties on fuel, alcohol and tobacco remained, According to the UK National Crime Agency and freedom of movement of people and cap- (NCA, 2018), more than 20% of the OCGs ital were guaranteed. known to, & investigated by the Northern Ire- There is a difference in fuel duty between NI land Police, have direct links with paramilitary and the Republic, and smugglers have exploit- (both loyalist and republican) organisations. ed this by buying fuel in the Republic and sell- 6.17 Emerging Threat: Cryptocurrencies: ing it in NI. For example, the excise rate in the The use of crypto currencies to launder crimi- Republic in 2017 was 13% lower than in NI for nal proceeds, particularly from cybercrime, has petrol, and almost 30% lower for diesel. There been identifed as a growing threat (see is no restriction on fuel for personal use, and it above), but also is a target identifed by crimi- is legal for a resident of NI to drive over the nals, much in the same way that a car or goods border, fll their tank, and drive back. However, are targeted to be stolen too. While global in transporting the fuel and then selling it is a nature, the crypto-asset industry is primarily crime. Smuggling fuel across the border has driven by companies based in North America, been a highly proftable crime, though actions China, India, and Western Europe, with taken to curtail this activity have been largely Switzerland and the UK leading the way. Out of successful. an estimated 550 plus companies engaged in According to the Cross Border Organised a material way in crypto-assets, Ireland is home Crime Threat Assessment49, published jointly to an estimated 2-3 only of these50. Ireland is in 2018 by both Republic and NI Police Forces, also largely off the map in other ways when it other main smuggling markets, in addition to comes to cryptocurrency, for example, there is fuel, are: tobacco, frearms, people, fnancial little or no indication of any material mining crimes and money laundering. Goods that are activity in Ireland generating new cryptocur- considered to be exposed to the potential for rency. According to an ING’s Global Survey51 increases in smuggling will depend on how on cryptocurrency published in June 2018, the trade between the 2 areas develops following average number of holders and or users of the UK’s withdrawal from the EU, the terms and cryptocurrency in Europe (based on the aver- application of the Trade deal, as well as deci- age from 13 countries - not including Ireland) sions by both countries on excise levels and was 9% (UK at 6%), with 25% on average ex- customs checks on the same goods. Whilst pected to own or use them in future.

Ireland - Threat Assessment - 2021 Page 19 of 45 Irish authorities have, in landmark actions, nomy, they are also a benefciary when eco- gone after and seized various forms of cryp- nomies experience signifcant downturns, and tocurrencies including $Bitcoin!#and $Ethereum!. as they benefted from the last economic These actions are considered by the CAB52 to crises, there are concerns that the crises cre- be the frst of its kind. ated by Covid 19 may also beneft organised crime. Some OCGs have sought to use COVID- 6.18 Emerging Threat: Brexit: Policing and 19 by exploiting the economic issues associ- Security: Under longstanding EU - UK ated with the pandemic and use this to launder arrangements, information sharing, extradition, illicit funds through cash intensive businesses co-operation and access to data on arrests and as well as investment in the real estate and other criminal matters benefted both coun- construction sectors. According to Europol, tries, that share a border and similar threats. there has been “an infltration into the eco- Following the trade and security agreement nomy” by criminal organisations in Europe, reached between the UK and the EU in late and Europol had been asked to carefully mon- December, 2020, a new relationship has come itor loans connected to the recovery fund, as into force, which seeks to replicate existing re- funds “are already being targeted by criminal lationships, but is not as strong or as useful. For organisations, and we expect more in the fu- example, whilst the UK wanted to retain access ture.”53 to EU databases, including the Schengen In- formation System 2 (SIS2), which includes De Bolle confrmed that OCG’s had already alerts on persons of interest, including terror- been praying on the public, as well as private ists and serious criminals, as well as on stolen companies & health authorities in many coun- objects such as cars and frearms, this has not tries, offering highly sought after products been permitted. such as disinfectant, face masks, thermomet- ers, mechanical ventilators & phantom cures Ireland is entitled to access SIS2 though it ap- for coronavirus, being made available for ex- pears it has not yet done so. Access to informa- ample online as well as more sophisticated tion on DNA, Fingerprints & Vehicle Registra- scams operandi using real corporate identities tions as well as Flight Passenger Data is though to offer victims the sale of products linked to still permitted. As a result it is expected that the pandemic only to disappear into thin air, Bilateral agreements and co operation be- after payment is made up front. tween the UK & Ireland will be promoted with co operation between the Irish police and The Police Service of Northern Ireland particularly seen as strong and to be further leveraged.

6.19 Emerging Risks: Covid 19: Whilst or- ganised crime benefts from a growing eco-

Ireland - Threat Assessment - 2021 Page 20 of 45 Section 6 - Key Threats in More Detail Continued - Country Summary - �

In this graphic the key threats (continued from Section 6) are focussed on areas of Ireland consid- ered at high risk as well as threats from third countries.

Ireland - Threat Assessment - 2021 Page 21 of 45 Ireland - Threat Assessment - 2021 Page 22 of 45 Section 7 - Sanctions & Embargoes - �

In this Section 7, the focus in on Sanctions and Trade with Iran is minimal, but does exist but is Embargoes. reducing. For example, from January to Octo- ber 2019, there were €57 million in exports, 7.1. Sanctions & Embargoes: Ireland adopts and only €1 million in the month of October both UN and EU sanctions and embargoes54. 2019. The largest component of exports is The sanctions enforced by the EU and UN in- vegetables. Imports from Iran over the same clude comprehensive trade sanctions against period were just €3 million, and zero in the other countries, embargoes that target arms, month of October 2019. The Tehran Times has fnancial sanctions as well as sanctions that are reported older trade data in 2017, reporting enforced against specifc individuals and limit- that Ireland’s exports to Iran in 2017 were val- ed sector specifc sanctions. The EU gives legal ued at €143.218 million, up from €71.845 mil- effect to Targeted Financial Sanction designa- lion in 2016, and Iran’s exports to Ireland were tions by the UN Sanctions Committees through €3.51 million in 2017, up from €1.629 million EU Council Regulations. Ireland is required to in 201657. For Syria, €12 million in exports were adhere to those EU measures. made from January to October 2018, and €14 Financial sanctions as well as asset freezing million in 2019. No imports were made. There restrictions are operated by the Irish Depart- was no trade reported for North Korea. ment of Finance but are handled by the Irish 7. 2 Embassies: Ireland has an embassy58 in Central bank. The Garda (Police) National Im- Iran, but not in Cuba, Syria or North Korea, migration Bureau possesses a database that while Cuba & Iran have embassies in Ireland, contains information about individuals that are but Syria and North Korea do not. subject to travel sanctions. The Central Bank of Ireland also has access to the EU consolidated Ireland has one named listing on OFAC!s list and a UN Sanctions Committees list relat- SDN and other sanctions lists US Treasury - 2020 ing to terrorism.

According to the Irish Government, Ireland ex- 7.3 OFAC Lists: Ireland has one named listing 59 ported €11.5 million worth of goods to Iran in on OFAC’s SDN and other sanctions lists. .

55 2017 , and discussions are open to sell dairy 7.4 Proliferation: According to the Peddling products, beef and sheep-meat. According to Proliferation Index60, Ireland is a Tier 1 Country trade statistics produced by Ireland’s Central (highest threat), but is ranked 14th best out of 56 Statistics Offce in October 2019 , trade with 55 Tier 1 countries with a control score of Iran, Syria and North Korea represented less 908/1,300. than 0.05% of Irish Trade.

Ireland - Threat Assessment - 2021 Page 23 of 45 Section 8 - Terrorism & Terrorism Finance - �

In this Section 8, the focus in on terrorism “certain groups... remain intent on disrupting threats & on terrorism fnance. the signifcant progress which has been achieved and perpetrating acts of violence. Re- 8.1. Terrorism/Extremism: According to the cent high-profle incidents, including attacks on FATF Report61, “as a result of efforts to target security personnel in Northern Ireland, the car domestic terrorist groups!#funding sources, the bomb in Derry and the murder of journalist groups!#methods have evolved, from funding Lyra McKee, are a reminder that we cannot be their activities through cigarette and fuel complacent.” smuggling, and violent crimes such as robbery, to "lower” risk activities (for the terrorist groups) The NRA highlights that Ireland faces both such as self-funding, taxation/extortion, and domestic and international threats. With re- collection of funds from community gatherings. gard to domestic threats, these are not direct- Irish authorities do not see a signifcant TF risk ed against Ireland itself, but against the UK related to international terrorism, particularly and NI in particular, via Irish Republican Para- when compared to other European jurisdic- military Groups. It is generally assessed that an tions.” attack in Ireland from this source is unlikely. However, the threat level in NI is considered to 62 The Global Terrorism Index ranked Ireland be “Severe” and in Great Britain to be “Sub- 62/138 and rated “Low” at 2.845/10 in 2020. In stantial” reduced in February 2021 from “Se- addition, Ireland is not mentioned in the 2019 vere” too. Terrorism Country Reports from the US. According to the UK Security Services64, “dis- sident republican terrorist groups pose the most signifcant threat to national security in Northern Ireland. There are four main dissident republican groups in Northern Ireland: the new IRA, the Continuity IRA (CIRA), Óglaigh na hÉireann (ONH – which recently split into two factions ONH and IRB), and Arm na Poblacht According to The World Economic Forum, Ire- (ANP). All oppose the peace process and re- land has a low terrorism incidence rate scoring gard violence as a legitimate means of achiev- 98.9/100 (higher scores are better) ranked ing a united Ireland. Since 2000 dissident re- 94/141 Countries. publicans have mounted attacks in Northern In Ireland’s Risk Assessment 201963 covering Ireland and between 2009 and 2017 they were broader concerns than ML/TF, it stated that, responsible for the deaths of two PSNI offcers, two British soldiers and two prison offcers. Dis- Ireland - Threat Assessment - 2021 Page 24 of 45 sident republican attacks often involve signifc- through purchase requiring access to funding.” ant risk to members of the public, who are also The NRA also states that, the “primary means regularly inconvenienced by the disruption in- by which these groups fund their activities is volved in the necessary police response to through a range of criminal activities including these and other security incidents (such as smuggling, extortion, robberies and the taxing hoaxes). Aside from attacks against the security of criminals involved in activities such as organ- forces, dissident republicans also conduct viol- ised prostitution, drug trade, etc. Counterfeit- ent attacks (shootings, beatings and intimida- ing has also more recently been used by some tion) against people within the communities, in groups. These funds can then be laundered an effort to generate community support and through cash enterprise such as licensed undermine the PSNI. Many dissident republic- premises and security companies or in the form ans are also heavily involved in criminal activit- of $loans!#to businesses fronted by persons with ies for personal gain, including smuggling and no obvious affliations to these groups.” extortion. There were 5 national security attacks The NRA confrms a low level of threat assess- in 2017 and the threat to life posed by dissid- ment posed by fnancing for international ter- ent republicans persists.” rorism, but nevertheless highlights, “the collec- As far as international terrorism, in other words tion of charitable funds either within communi- extreme Islamic inspired terrorism, the NRA ty institutions or by charities/NGOs in states that “Ireland is not subject to the same general.... [with] such funds may be collected levels of concern regarding the fnancing of for the stated reason of supporting humanitari- international terrorist activity due to the fact an relief in confict zones. While there is no evi- that the numbers of supporters of international dence to suggest that such funds are being terrorism in the State is small when compared misused, it can be diffcult to establish the bona with other European jurisdictions, with little fdes of such groups. Similarly while the use of evidence to show any coordinated approach to credit cards near confict zones or the transfer fundraising in support of international terror- of funds through accounts to such regions are ism. Intelligence suggests that there is no real indicators of terrorist fnancing it must be $infrastructure!#in place to facilitate fundraising borne in mind that there are a number of indi- for international terrorism at any signifcant viduals in the State who legitimately send funds levels.” to their countries of origin on a regular basis.”

8.2 Terrorism Finance: The NRA confrms that the, “costs associated with domestic terrorist acts are, for the most part relatively small. The material used in such acts can be procured of- ten through theft; though certain more sophis- ticated material may have to be procured Ireland - Threat Assessment - 2021 Page 25 of 45 Section 9 - Money Laundering - �

In this Section 9, the focus is on Ireland’s vul- cially where the origin or path of funds is not nerability to money laundering. fully disclosed. The potential ML/TF risk associ- ated with such international transactions in- 9.1 Money Laundering: Money laundering creases when funds are transmitted to or from methods and techniques are used in Ireland, jurisdictions outside EEA, which may have in- with the most likely being cash based money adequate AML regulation and controls.” laundering, followed by trade based money laundering, The fnancial crime risks across Ireland can be differentiated, with the urban areas, the border Vulnerability to ML NRA areas and the main transit locations likely to Retail Banking High present increased risks, in particular around Money Remittance Firms High Dublin, Limerick, Meath, Kildare, Louth & Cork Bureau de Change High Non Retail Banking / Funds/Funds Administrators Medium High 9.3 Cash Based Money Laundering: Accord- Investment Firms / Private Members Clubs Medium High ing to a 2018 report which mapped the risk of High Value Goods Dealers Medium High Serious and Organised Crime infltration in Eu- Trust & Company Service Providers Medium High 65 Legal Services / Accountancy Services / Notaries Medium High ropean Businesses , Ireland does not have a

None Proft Organisations Medium - Low high level of cash intensity, which appears to Property Service Providers Medium - Low be slightly lower than the EU average, though Payment Institutions (other than remitted) Medium - Low still signifcant, with 43% of all payment trans- Life Assurance Medium - Low

Asset Managers Medium - Low actions made in cash, and ranked 21st out of

Credit Unions / Money Lenders Medium - Low 28 Countries.

Retail Intermediaries Low

TCSP - Credit or FI Subsidiaries Low Ireland’s shadow economy estimated to constitute 16.9%, or US$64.7 billion - for 9.2 Higher Risk Areas: According to the NRA, 2018. More Project - 2018 3 sectors are considered “High” vulnerability for money laundering, retail banking, money Cash economies make it easier to launder remittance frms and bureaux de change. For criminal funds, and for organised crime to in- retail banking, the NRA states that, “while the fltrate legitimate activity. In addition, FATF likelihood of a specifc customer or transaction warned that "although decreasing, cash con- being used for ML or TF is low, the volume of tinues to be an important part of the domestic both poses a key challenge to banks in terms of economy and cash-intensive sectors such as monitoring and identifying suspicious activity. dealers in high value goods, money remittance In particular, the number of international trans- and currency exchange, as well as retail banks, actions creates opportunities for misuse espe-

Ireland - Threat Assessment - 2021 Page 26 of 45 pose vulnerabilities for money laundering/ter- constitute a factor of attractiveness for foreign rorist fnancing.” OCGs willing to invest criminal proceeds in the legitimate economy67. This risk is however mit- The same 2018 report which mapped the risk igated by a number of factors, including a of Serious and Organised Crime infltration in comparative lack of fnancial secrecy, which, European Businesses66, also reported on the according to the Tax Justice Network!s Secrecy shadow economy in Ireland, and ranked it 21st Score (Tax Justice Network, 2018), ranks Ire- among 28 EU countries, with the shadow land 21st among EU’s 28 countries. economy estimated to constitute 16.9%, or US$64.7 billion for 2018. According to Global Financial Integrity’s (“GFI”) reporting in 2015, TBML involves the deliber- According to the NRA, law enforcement intel- ate falsifcation of the value or volume of an ligence confrms that criminal proceeds gen- international commercial transaction, and is erated in cash, as in the case of fuel laundering the largest component of illicit fnancial fows, - but where the activity is unlikely to be differ- particularly from developing countries.68 GFI ent for the laundering of any other cash pro- estimate that trade misinvoicing is equivalent ceeds, are likely laundered by any, or a combi- to 18% of total developing country trade with nation of, the following: advanced economies. In 2017, Ireland gener- • Establishing or becoming involved in cash ated approximately US$219 billion from ex- intensive businesses such as high value ports and US$98 billion from imports69, most goods dealers (HVGDs), wholesale business- of which were with US and European countries es, transportation businesses, flling stations; (with the top 5 countries representing 75% of all trade). Based on 2% of Irish trade estimates, • Bureau de change; it would suggest that the TBML values for Ire- • Money transmission businesses; land could be estimated at US$1.14 billion.

• Cash mules; and 9.5 Other Money Laundering: Securities, Transaction and Virtual Currency laundering • Third party money laundering, and are not considered as signifcant, though nev- • Trade-based money laundering ertheless important techniques, likely increas- ingly popular as other techniques come under 9.4 Trade Based Money Laundering greater scrutiny. These techniques also offer (“TBML”) / Trade Misinvoicing: Ireland has a alternative solutions, depending on the need favourable tax regime, which is attractive to of the criminal. large multinational companies. It may also .

Ireland - Threat Assessment - 2021 Page 27 of 45 Ireland - Threat Assessment - 2021 Page 28 of 45 Section 10 - Response - �

In this Section 10, the focus is on Ireland’s level role in this process. Payment institutions, which of resilience and response. utilise Ireland as a base to "passport” to the rest of Europe through an extensive network, fur- 10.1 FATF: The evaluation of Ireland was pub- ther increase the need for a close supervision lished in 201770. The report states that, “while of the sector.” Ireland appears to have a strong understand- ing of ML risks based on domestic crime, more could be done to clearly identify Ireland!s in- ternational ML risks, particularly considering that Ireland is a highly interconnected economy & with a large fnancial sector in relation to GDP. The NRA could be further supported by quantitative data.” A follow up Report was published in 201971 The report further stated that, “Ireland has Based on a simple scoring model developed identifed its main ML/TF threats as organised by FCN, Ireland is rated at 75% for technical crime groups and former local paramilitary compliance and 48% for effectiveness. groups whose activities relate to drug traffck- ing, human traffcking and migrant smuggling, Key results for 10 Core Recommendations fuel laundering, and fraud (including VAT Technical Compliance with 40 Recommenda- fraud).” tions were: R8 (NPOs) - PC, R10 (CDD) - LC, R12 (PEPs) - C, R13 (CBR) - PC, R14 (MVTS) - It also stated that, “domestically although de- LC, R15 (NewTech) - LC, R22 - (DNFPBs CDD) - creasing, cash continues to be an important PC, R26 (FI Supervision) - C, R28 (DNFPBs Su- part of the domestic economy and cash-intens- pervision) - LC & R29 (FIU) - C. Taking these ive sectors such as dealers in high value goods, core elements, FCN scores Ireland at 62%. money remittance and currency exchange, as well as retail banks, pose vulnerabilities for ML/ On Effectiveness, Ireland received no “Highs”, TF” and “Internationally, the fnancial sector, 5 “Substantials”, 6 “Moderates”, and 0 “Lows.” particularly the investment funds sector is seen Key IO results were: IO3 (Supervision) - SE, IO4 as a vulnerable area for ML. Complex owner- (Preventative Measures) - ME, IO6 (FIU) - SE ship structures and reliance on third-parties to and IO8 (Confscations) - ME. Taking into ac- undertake customer due diligence complicates count these core elements, FCN scores Ireland the identifcation of benefcial ownership and at 50% for effectiveness for these key areas. could hide potential money laundering For more details see the results against each of schemes. Gatekeepers also play an important

Ireland - Threat Assessment - 2021 Page 29 of 45 the 40 Recommendations and 11 Immediate aggravated by the relaxation or postponement Outcomes below in Section 11. of legal provisions regulating benefcial owner- ship”73. 10.2 Financial Institutions: Ireland was rated “Compliant” for R9 (FI Secrecy Laws), R12 Ireland is nevertheless rated “Compliant” by (PEPs) & R16 (Wire Transfers). For both R10 the OECD Global Tax Forum74. In its latest re- (CDD), R11 (Record Keeping) and R14 (Money view carried out in 2017, Ireland was rated or Value Transfer Services) Ireland was rated Compliant in all 10 sub categories, including “Largely Compliant” and for R13 (Correspon- for A1, Ownership & Identity Information, A3 dent Banking) rated “Partially Compliant.” Banking Information. See Section 10.10.4 be- Identifed weaknesses on correspondent bank- low. ing relate to intra EU banking, where Irish 10.5 Regulatory Supervision: Ireland scored Banks do not need to apply FATF measures 1.6 (-2.5 to +2.5) (15/193) in the country rank- with respect to EU-based correspondent insti- ings by the World Bank for regulatory quality tutions, due to EU ML Directives. For FI fnes (2018)75. and penalties see Section 10.5 below.

10.3 Designated Non Financial Businesses & Professions (DNFPB’s): Ireland was rated “Largely Compliant” for R22 (DNFPB CDD) & R23 (DNFPBs Other Measures). Casinos are prohibited in Ireland, although Private Mem- bers Clubs at which gambling activities are carried out are covered under AML/CTF oblig- Ireland was rated “Compliant” for R26 (Regu- ations. Real Estate Agents, Dealers in Precious lation & Supervision of FIs) & for R27 (Powers Metals & Stones and other High Value Goods of Supervisors), and “Largely Compliant” with Dealers are subject to AML/CTF obligations, R28 (Regulation & Supervision of DNFPBs). on cash transactions above €15,000. Ireland was also rated “Compliant” for R35 10.4 Benefcial Ownership Registers of Le- (Sanctions). gal Persons: Ireland is rated as “Largely The Central Bank of Ireland (as regulator), took Compliant” with FATF R24 (Transparency & BO strong action against Ireland’s largest Banks of Legal Persons), & R25 (Transparency & BO of including imposing fnes. The Bank of Ireland Legal Arrangements). As an EU Member State, was fned €3.15 million after admitting 12 AML Ireland is obliged to introduce a central public breaches, Allied Irish Bank (AIB) was fned al- register, and is committed to doing so72. TI has most €2.3 million after admitting six breaches, recently warned that due to COVID 19 “Cor- Drimnagh Credit Union was fned €125,000, ruption and money laundering risks may be

Ireland - Threat Assessment - 2021 Page 30 of 45 and an Italian life assurance frm, Intesa San- According to the Central Bank of Ireland’s Fi- paola, was fned €1 million for four breaches of nancial Stability Review78 published in 2019, a AML laws. Ulster Bank was fned €3.32 million risk identifed is the possibility of Irish Banks in 2016 for similar breaches. More recently in (as with EU banks more generally), taking on 2019, the Central Bank of Ireland imposed a more risk in order to achieve long-term ROE €1.6million fne on JPMorgan for “serious” targets of between 10-12%. Such target ROE regulatory failings in its Dublin fund adminis- levels are signifcantly above the current level tration arm, relating to failures on controls and recorded by many EU banks, including the approvals around outsourcing. Irish retail banking system overall.

Signifcant improvements in the larger The EU levied a €2 million (US$2.3 million) fne banks in Ireland following CBI fnes on Ireland for failing to properly bring money- FCN - 2020 laundering and terrorist-fnancing rules in line

It’s likely that signifcant improvements in the with European Union law by the deadline of larger banks in Ireland have followed after July 2017. Ireland has since implemented the these fnes and penalties were levied. laws in question, albeit by December 2019.

The CBI76 issues public AML feedback, includ- 10.6 Financial Intelligence Unit: Ireland’s FIU ing 2 publications in 2020, with a Dear CEO is embedded within the Garda National Eco- letter to Regulated Entities summarising AML/ nomic Crime Bureau (GNECB) which is the re- CFT fndings from inspections & an AML Bul- cipient of Suspicious Transaction Reports letin on Transaction Monitoring. (STRs) in the country. The FIU is supported by the Money Laundering Investigation Unit Following its annual review of so called “signif- (MLIU), which supports the FIU within GNECB icant institutions,” at the end of 2018, the Eu- and it investigates complex money laundering 77 ropean Central Bank maintained that the cases and/or cases which have cross- jurisdic- Bank of Ireland and AIB, Ulster Bank and tional links, as well as extracting information Citibank Europe were “signifcant.” The third from the analysis of STRs allowing for the insti- largest domestic bank, Permanent TSB, was gation of criminal investigations. This police removed from the list. It also added to the led model is an approach favoured by 10/28 2019 list several large banking groups that EU countries, with 12/20 opting for an adminis- have relocated their activities from the UK, trative model, 5 a hybrid model, and 1 a Ju- and/or expanded their operations in Ireland ridical model. due to Brexit concerns, namely Barclays Bank Ireland, where the CBI anticipated an expan- The FIU is staffed by 11 staff, including two sion of the bank’s activities due to Brexit, as gardaí covering a Terrorist Financing Intelli- 79 well as a subsidiary of Bank of America - Merrill gence Unit . Lynch.

Ireland - Threat Assessment - 2021 Page 31 of 45 Staffng levels at overseas FIU’s80, can be com- institutions, and 1,545 by others (including by pared with Ireland with estimates for 2017 for MSBs -200 and money remitters - 52). Canada at 350, Germany at 289, France at 150 Comparing these fling rates to those across & UK at 80 & Switzerland at 20. The number of the EU, Ireland fles more than most, at about STRs received can also be compared. In 2014, 2% of the EU total, albeit the EU average for example Germany’s FIU received 24,054 across all countries for 2017 (excluding the UK SARs, France received 36,715, the UK received and the Netherlands) is at 17,300. In 2016, 354,186 SARs and Ireland received 21,682. banks were responsible for fling approximate- The FIU has been a member of the Egmont ly 68% (14,900) of all STRs in Ireland, and 62% Group since 2001 and is a member of Interpol. (14,155) in 2017.

The FIU was rated “Partially Compliant” for According to Europol81, STRs submitted refer- R29 (FIU) after the 2017 MER, because Ireland encing terrorism fnance (TF) in Ireland are could not demonstrate that the FIU is opera- amongst the highest in the EU, alongside Aus- tionally independent and that the FI had a lim- tria which otherwise averages below 1%. In Ire- ited ability to conduct strategic analysis under land’s case, TF related STRs represented 3.84% its current IT systems. This has since been up- of the total fled in 2013, and 3.38% in 2014. graded to “Compliant” following legislative Furthermore, Europol estimated average esti- changes to ensure independence and by ac- mates for the amounts involved in STRs across quiring GoAML, which enhanced its capacity the EU at approximately 0.1% of GDP (exclud- to undertake complex operational and strate- ing Italy), in 2012, 2013 and 2014. In an Irish gic analysis. context, this would amount to €380 million, albeit Ireland does not report publicly on STR values. In 2017, there were 134 outgoing en- quires (based on STR information) made by the FIU in Ireland to foreign FIUs, and 305 incom- ing enquiries received by the FIU in Ireland from Foreign FIUs.

The breakdown by STRs into categories based

Ireland’s FIU has seen a sharp rise in total STRs on predicate offences is also something Ire- referred to it, rising from 12,390 in 2012 to land does not publicly report. Europol provid- 21,682 in 2016, 24,398 in 2017 and 23,422 in ed average EU fgures on this for 2013-14, 2018, with the number of reports in 2017 the from member country FIU reporting. The main highest since 2009. Of the 24,398 reports fled underlying predicate offence relating to EU in 2017, 15,155 was reported by the banks, STRs are tax fraud at 39%, fraud at 30%, drugs 6,179 by credit institution’s, 1,646 by payment at 15%, cybercrime at 6%, corruption at 4%,

Ireland - Threat Assessment - 2021 Page 32 of 45 piracy of goods at 3%, human traffcking at 2%, Ireland was rated as “Largely Compliant” for robbery at 1%, and terrorism fnance <1%. R34 (Guidance & Feedback) after the 2017 MER but has since improved and is now rated Similarly, Europol provides EU averages on the as “Compliant.” underlying reason for suspicion being raised in STRs. The main reasons in 2013-14 involved 10.7.1 Law & Order: According to Eurostat82, “Cash” which was present in 38% of cases, with Ireland spends an estimated 0.9% of GDP 19% related to “Cash Deposits”, 14% on “Cash (2018) on law and order, with 0.5% spent on Withdrawals”, and 5% on “Cash Transactions.” policing, 0.2% on law courts and 0.1% on pris- Cash was followed then by “Unusual Be- ons and 0.1% on others. haviour” at 12%, “Front Companies” at 4%, Fraudulent Transactions at 4%, “Phishing/ Pharming” at 3%, the “Economic Background” of the Customer at 3%, “Forged Documents” at 3%, High Risk Countries at 2%, “Use of MSBs” at 2%, “Offshore Based Companies” at 2%, “Open Source Information” at 2%, “Frequent

Transactions and Small Amounts” at 1% ,and This would represent approx US$3.45 billion in “Frequent Transactions and Large Amounts” at all, with US$2.3 billion on policing, US$766 1%. million on law courts & US$383 million on prisons. According to the Irish government it- Conversion rates, according to Europol on av- self, the budget for the entire Irish Justice sys- erage across the EU for 2013 and 2014, were tem in 201883 was approx 0.8% of GDP at €2.6 approximately 10%, meaning that STRs re- billion, covering; Garda Siochána (€1.650 bil- ceived were assessed and either forwarded to lion), Prisons (€341 million) & Law Courts (€132 law enforcement or some other body, or were million). considered of particular use or value in the criminal justice process. Its probably that the Irelands spending on law and order is much 10% fgure is likely overstated for various rea- less than the EU average of 1.5% (excluding sons. The Europol report includes reference to fre services) and lags many other large coun- Ireland as having a 100% conversion rate, as all tries, including Germany (1.4%), France (1.4%), STRs received are reviewed, for example by Italy (1.6%), Spain (1.6%) & UK (1.7%). Only one linking an STR to an Irish taxpayers record, as- country Denmark in fact spends less (0.8%) signed a risk rating, and the data is incorporat- with 2 others spending the same, namely Lux- ed into each taxpayer’s risk profle, with inter- embourg & Finland. ventions and investigations,(where appropri- ate) considered. According to The World Economic Forums Global Competitiveness Index 201984 under

Ireland - Threat Assessment - 2021 Page 33 of 45 Pillar 1 Institutions, Ireland’s rating for “police tion, detection and investigation, as well as na- service reliability” is at 78.1/100 and ranked tional security, road security and community globally at 27/141 (in all cases higher scores policing. It is currently undergoing a process of are better). modernisation to meet the demands of mod- ern policing and better serve the people of Ire- 10.7.2 Prisons: The Irish incarceration rate is land. At the heart of this process is the concept at 79 per 100,000 for people in prison85 in of policing by consent. Garda offcers are un- 2018. At the start of 2021 this has reduced to armed and uniformed.” The Interpol National 74 per 100,000, with 3 729 people in prison in Central Bureau (NCB) in Dublin “is part of the Ireland86, down from a high in 2012 of 4,318 Security and Intelligence specialised region, (94 in 100,000). whose role is to identify and analyse the threat to the state from terrorist and organised crime groups, and serve as Ireland!s central point of contact with the global law enforcement com- munity”.

According to the 2020 OSAC report88 “Police response to crime in Ireland is generally ade- According to the Irish Prisons Service87, of quate and timely within the larger urban areas, 5,690 sentence committals in 2019, 1,277 re- especially Dublin, but considerably slower in lated to theft and burglary offences, 983 to or- the more rural areas of Ireland”. ganised crime, 458 to drug offences, 468 to attempted murders or assault offences, 159 to Ireland’s Department of Justice89, allocated weapons and explosive offences, & 100 to €1.76 billion to An Garda Síochána for 2019, Fraud. which was an increase of approximately 2% over the allocation for 2017 and 6.5% com- 10.7.3 Law Enforcement: Ireland is rated pared to 2015. Total staffng for 2018 is 16,880, “Compliant” for R30 & R31 (Law Enforcement comprising 14,032 Guarda Members, 2430 Responsibilities & Powers). Guarda staff & 528 Reserve Members, with a According to Interpol Ireland, “The Republic of plan to reach 21,000 by end 2021. Ireland has one national civilian police force, There have been no foreign bribery prosecu- called "An Garda Síochána”, meaning $Guardi- tions since at least 2014 - see Section 10.11 ans of the Peace of Ireland!. It has 14,500 staff below. members and provides both local and national law enforcement services. It is commonly re- For Human Traffcking convictions, there have ferred to as "Garda”. Some of the core functions been no convictions since at least 2013, ac- of An Garda Síochána include crime preven- cording to the US Traffcking in Persons Report

Ireland - Threat Assessment - 2021 Page 34 of 45 202090 report, which reports that the Irish In Ireland, in 2014, according to the NRA, the government “the government has not obtained CAB froze €6,760,000 in assets, secured the a traffcking conviction since the law was forfeit of €460,000 to the State, recovered ap- amended in 2013, which weakened deter- proximately €3 million in taxes, and recovered rence, contributed to impunity for traffckers, social welfare debts of approximately and undermined efforts to support victims to €335,000. The Revenue Commissioners im- testify. The government continued to have sys- posed fnes of €1,173,620. tematic defciencies in victim identifcation, re- €7 million seized or frozen, €2.2 million ferral, and assistance. The government contin- confscated, €3 million forwarded by Rev- ued to lack specialised accommodation and enue Commissioners and €323,000 in So- adequate services for victims, and the amend- cial Welfare overpayments recovered ed working scheme for sea fshers increased Various - 2017 their vulnerability to traffcking.” In 2016, assets worth more than €4m were

The Global Slavery Index91, gave Ireland a seized or frozen by various authorities includ- good government response of “BB” in 2018. ing the Criminal Assets Bureau and the DPP!s assets seizing unit. A further €6.3m in tax re- 10.8 Statistics: Ireland is rated “Partially lated offences was identifed by the Revenue Compliant” for R33 (Statistics) after the 2017 Commissioners. MER.” The FUR 2019 has not changed this rat- ing. In 2017, assets worth more than €7 million were seized or frozen by various authorities According to the Europol report the likelihood including the Criminal Assets Bureau and the of successful asset recovery across the EU is DPP!s assets seizing unit. The Criminal Assets low. Europol fndings show that from 2010 to Bureau forwarded in excess of €2.2 million to 2014, just 2.2% (€2.4 billion or 0.018% of EU the Exchequer. In addition, in excess of €3 mil- GDP) of the estimated proceeds of crime were lion was forwarded under the Revenue provi- provisionally seized or frozen, and only 1.1% sions, and €323,000 was recovered in respect (€1.2 billion or 0.009%) of the criminal profts of overpayments under social welfare provi- were ultimately confscated in the EU. These sions in 2017. The Criminal Assets Bureau had can be averaged to represent confscation a budget of €6.7 million in 2016, increased to rates of €1.7 per person (and seizure rates of €8.2 million in 2017. According to the CAB between €4.8 and €7.6 per person). 2018 report, staffng levels for 2017 included According to the Gardai’s Drugs and Organ- 91 offcers, with 47 from Guardia, and 17 from ised Crime Bureau , they have seized €168m Revenue. The CAB, as well as taking action to worth of drugs, 109 frearms, more than 3,400 seize assets, generates a pipeline of potential rounds of ammunition and €11m in cash, from actions by targeting assets across Ireland and 2016 to end 201992. abroad. Ireland - Threat Assessment - 2021 Page 35 of 45 Dublin, Limerick, Meath, Kildare, Louth & lished to focus more on international threats Cork and risks. Most targeted for criminal asset seizures by CAB - end 2018 10.10 Other Indices: A number of important sources identify both indirect and direct indi- As at the end of 2018, Criminal Asset Targeting cators that contribute to an assessment of re- and Seizures: Geographic Distribution of Tar- sponse to the fnancial crime threats Ireland gets under investigation by CAB totalled 973, faces, which include the following: with the Dublin area representing 462 targets, Limerick 78, Meath 40, Kildare 38, Louth 33, 10.10.1 Freedom: Freedom House’s, Free- and Cork 31 (Cork City 18). Other counties dom in the World Index, ranks countries and were between 20-29,10-19, and 4-9. In Dublin, their citizens as either, “free” “partly free” or the breakdown in Dublin was 177 in West “not free.” Ireland scored 97/100, and is rated# Dublin, 110 in South Dublin, 80 in North "free93”. Dublin, 46 in North Central, 37 in South Central and 12 in East Dublin. There are also 23 targets According to the Heritage Foundation’s 2019 94 under investigation outside the country. This Index of Economic Freedom , Irelands eco- targeting by CAB, can be used to highlight nomic freedom score is 80.9/100 making its where likely increased threats across the coun- economy one described as “free”. In the most try are present from a fnancial crime perspec- recent update for 2021, Ireland has improved tive, and also by the same token, geographic its score to 81.4 and ranking to 5/178. Its over- risks are reduced. Additional geographic risks all score has increased by 0.5 points, “primarily to note include Northern Ireland, (TF, smug- because of an improvement in judicial effec- gling), The United Kingdom more broadly tiveness.” Ireland is ranked 2nd among 45 (people smuggling, drug traffcking, the countries in the Europe region, and its overall Netherlands & Spain (drug traffcking), & Viet- score is above the regional and world aver- nam (human traffcking, and cannabis). ages.

10.9 Financial Information Sharing Partner- 10.10.2 AML Indices: According to the 95 ships (FISPs): Ireland has established a Finan- 2019 fndings, Ireland scored 4.46/10 in the cial Information Sharing Partnership, known as Basel AML Index, rated 106/141 countries - 1 being the worst). Ireland’s Joint Intelligence Group (JIG). The JIG is led by the Garda National Economic Crime 10.10.3 Global Slavery Index: Whilst Ireland Bureau (GNECB) and has representation from has a low incidence of human traffcking, (1.7 in the private sector, principally, the anti-fnancial 1,000 estimating victims at approximately 8,000), crime teams from the main domestic banks the Global Slavery Index96 2018 gives Italy a good and a major MSB. In a recent development an government response of 57.7 and “BB”, which is the International Banks forum has also been estab- same as the overall regional average of “BB”.

Ireland - Threat Assessment - 2021 Page 36 of 45 10.10.4 Global Tax OECD: Ireland is a Global 10.12 Reform: In September 2020, the Crimi- Forum Member that is rated “Compliant” by nal Justice (Money Laundering and Terrorist the OECD Global Tax Forum97. In its latest re- Financing) (Amendment) Bill 2020 was offcial- view carried out in 2017, Ireland was rated ly published which transposes the criminal jus- Compliant in all 10 sub categories, including tice elements of the 5th EU Money Laundering particularly for A1, Ownership & Identity In- Directive (EU 2018/843) and strengthens exist- formation, A3 Banking Information & B1 Ac- ing money laundering and terrorist fnancing cess to Information. Ireland has agreed to Ex- legislation. change of Information on Request and the Au- Across the EU an AML Action Plan was an- tomatic Exchange of Information. nounced by the EU Commission101 on 7th May, 10.10.5 Cyber security: According to the 2020 and accompanying the announcement in- 2018 Global Cybersecurity Index (GCI)98, Ire- cluded an EU Factsheet 102 described as intended land scored 0.784/10 and is described as hav- as "Closing the door on dirty money.” The Plan aims ing a “High” level of commitment ranked 38th to increase effectiveness, based on 6 pillars. globally out of 175, and 23rd out of 46 in the • Effective application of EU rules Europe Region in terms of cybersecurity. • Single EU Rulebook 10.11 Anti Corruption Commitments: Ire- land has ratifed the United Nations Conven- • EU level supervision tion against Corruption (UNCAC) and the Or- • A co ordination & support mechanism for EU ganisation for Economic Co-operation and FIU’s Development (OECD) Anti- Bribery Conven- tion. • Enforcing EU level criminal laws and informa- tion exchange According to the OECD, there have been zero foreign bribery cases that have led to prosecu- • A stronger EU in the world. tions from 1999 - 201999. This compares to 268 These have been informed by and will be prosecutions with sanctions in the USA over shaped by work from the European Banking the same period, 352 in Germany, 33 in the UK Federation103 and think tank CEPS104. & in South Korea & 32 in France which make up the Top 5.

As a result TI100 rates Ireland as “Red” on rank- ings of enforcement of OECD obligations on corruption, therefore increasing the risks that corrupt trade is taking place.

Ireland - Threat Assessment - 2021 Page 37 of 45 Section 11 - Detailed FATF Results & FCN Scoring - �

The country evaluation of Ireland105 was published in November, 2017 and a follow up Report was published in 2019106. Ireland has 7 “Partially Compliant” ratings for R6 (Targeted Financial Sanctions related to Terror- ism/Terrorism Finance), R7 (Targeted Financial Sanctions related to Proliferation), R8 (NPOs), R13 (Corres- pondent Banking), R22, (DNFBP CDD), R32 (Cash Couriers) and R33 (Statistics). Ireland is not included on the FATF Strategic Defciencies/Call to Action lists. Ireland reported 6 “Moderately Effective” Ratings for IO4 (Pre- ventative Measures), IO5 (Legal Persons & Arrangements), IO7 (ML Investigations & Prosecutions), IO8 (Con- fscations), IO9 (TF Investigations & Prosecutions), IO10 (TF Preventative Measures & Financial Sanctions).

FATF 40 Recommendations - “Technical Compliance“ � !

R1 R2 R3 R4 R5 R6 R7 R8* R9 R10*

LC C C C LC PC PC PC C LC

R11 R12* R13* R14* R15* R16 R17 R18 R19 R20

LC C PC LC LC C LC LC LC C

R21 R22* R23 R24 R25 R26* R27 R28* R29* R30

C PC LC LC LC C C LC C C

R31 R32 R33 R34 R35 R36 R37 R38 R39 R40

C PC PC C LC C C LC C LC

Key: C = Compliant, LC = Largely Compliant, PC = Partially Compliant, NC = None Compliant, * = core

FATF 11 Immediate Outcomes - “Efectiveness”

IO1 IO2 IO3* IO4* IO5 IO6* IO7 IO8* IO9 IO10 IO11

SE SE SE ME ME SE ME ME ME ME SE

Key: HE = Highly Efective, SE = Substantially Efective, ME = Moderately Efective, LE = Low Efective, * = core

FATF Overall Scores by FCN

1. FATF 40 Recommendations - “ Technical Compliance“ 75

2. FATF 10 Core* Recommendations - “ Technical Compliance“ 62

3. FATF 11 Immediate Outcomes - “ Efectiveness“ 48

4. FATF 4 Core* Immediate Outcomes - “ Efectiveness“ 50

Scoring by FCN = C/HE -3, LC/SE -2, PC/ME -1, NC/LE -0. Total score divided by total available score x 100

FATF Strategic Defciency List No

Ireland - Threat Assessment - 2021 Page 38 of 45 Section 12 - Remittance & Migration Data - �

According to the World Bank107, remittances inbound in 2018 were approx US$623 million (0.2% of GDP) down from US$719 million in 2014 and outbound were US$1,659 million (0.4% of GDP) in 2018 down from US$1,960 in 2014.

According to the World Bank108 the top 10 recipient countries are estimated at US$1,522 million (70%), lead by Nigeria, UK, Poland, France & India. The full list of recipient countries receiving US$10 million or more is set out below. For infows into Ireland the Top 6 countries represent 88% of the total in 2017, or US$538 million/US$623 million, from UK, US, Australia, Canada, Germany & Spain.

Outbound Remittances in US$ millions from Ireland - 2017 estimates by World Bank

Country US$ mio Country US$ mio Country US$ mio Country US$ mio

Nigeria 473 China 76 Germany 52 Italy 26

UK 243 Philippines 75 Czech Rep 43 Australia 23

Poland 205 Spain 70 Slovakia 39 Brazil 15

France 131 Hungary 69 Belgium 33 Sweden 15

India 100 Latvia 66 Pakistan 32 Bermuda 14

Lithuania 80 USA 56 Romania 27 Thailand 12

Total 2017 2161

Inbound Remittances in US$ millions to Ireland - 2017 estimates by World Bank

Country US$ mio Country US$ mio Country US$ mio Country US$ mio

UK 320 Australia 60 Germany 13 Spain 13

USA 112 Canada 20

Total 2017 623

Ireland - Threat Assessment - 2021 Page 39 of 45 Appendix 1 - FCN Threat Types Mapping - �

Based on this Ireland Threat Assessment, the following FCN Threat types are risk rated “High”, “Moderate”or “Not Rated”. This can be converted into “Higher” “Medium” and “Lower” as appropriate. The mapping has been carried out based on a full analysis of the information contained in this Threat Assessment, in particular from the sources and summaries set out in Section 6 above.

Ireland Threat Assessment 2021 - Threat Mapping to FI AML /CTF Programme - � !

Copyright: Financial Crime News / Metriqa Limited - 2021 - All rights reserved

Ireland - Threat Assessment - 2021 Page 40 of 45 Appendix 2 - Sources - � #

These are the main sources for the Ireland Threat Assessment by Financial Crime News/Metriqa Limited.

This Threat Assessment, has been generated by compiling, assessing and summarising open source available information. Critical assessments from fnancial crime experts reveal the salient inputs, insights and conclusions to formulate this Threat Assessment. No reliance, except as otherwise represented should be taken by anyone, nor offence taken even by those mentioned, from the pub- lisher, where reasonable responses are taken from such sources as are available, in order to aid the fght against fnancial crime. In case of objection to anything included in this threat assessment, or otherwise including a request for reasonable comment or argu- ment please contact the publisher directly. This Threat Assessment is copyrighted and protected by FCN/Metriqa Limited. This should not be used by commercial organisations and for in connection with commercial activities without a licence from FCN/Met- riqa Limited.

Ireland - Threat Assessment - 2021 Page 41 of 45 Endnotes - �

1 See: https://migrationdataportal.org/data?i=stock_abs_&t=2019 2 See: https://www.cia.gov/the-world-factbook/ 3 See: https://www.gfmag.com/global-data/non-economic-data/worlds-safest-countries-2019 4 See: https://www.gov.ie/en/organisation/department-of-fnance/?referrer=http://www.fnance.gov.ie/sites/default/fles/IFS2020.pdf 5 See: https://datareportal.com/reports/digital-2020-ireland?rq=Ireland 6 See: https://www.knomad.org/data/remittances?tid%5B146%5D=146 7 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 8 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 9 See: Savona Ernesto U. & Riccardi Michele (Eds.), 2015, From illegal markets to legitimate businesses: the portfolio of organised crime in Europe. Final Report of Project OCP – Organised Crime Portfolio, Trento: Transcrime – Università degli Studi di Trento, (“OCP”), p 37 10 See: https://www.socialistsanddemocrats.eu/sites/default/fles/2019-01/the_european_tax_gap_en_190123.pdf 11 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 12 See: https://thefnancialcrimenews.com/global-threat-assessment-2018-by-john-cusack/ 13 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 14 See: https://www.state.gov/wp-content/uploads/2019/03/INCSR-Vol-INCSR-Vol.-2-pdf.pdf 15 See: http://www3.weforum.org/docs/WEF_TheGlobalCompetitivenessReport2019.pdf 16 See: https://images.transparencycdn.org/images/2020_Report_CPI_EN.pdf 17 See: Ernesto U. Savona and Michele Riccardi (eds), 2018, Mapping the risk of Serious and Organised Crime infltration in European Businesses – Final report of the MORE Project Milano: Transcrime – Università Cattolica del Sacro Cuore. © 2018. See: http://www.tran- scrime.it/wp-content/uploads/2018/12/MORE_FinalReport.pdf 18 See: https://ec.europa.eu/home-affairs/what-we-do/policies/organized-crime-and-human-traffcking/corruption/anti-corruption-re- port_en 19 See: https://ec.europa.eu/commfrontoffce/publicopinion/index.cfm/ResultDoc/download/DocumentKy/81007 20 See: Savona Ernesto U. & Riccardi Michele (Eds.), 2015, From illegal markets to legitimate businesses: the portfolio of organised crime in Europe. Final Report of Project OCP – Organised Crime Portfolio, Trento: Transcrime – Università degli Studi di Trento, (“OCP”), p 37 21 See: https://www.interpol.int/en/Who-we-are/Member-countries/Europe/IRELAND 22 See: Ernesto U. Savona and Michele Riccardi (eds), 2018, Mapping the risk of Serious and Organised Crime infltration in European Businesses – Final report of the MORE Project Milano: Transcrime – Università Cattolica del Sacro Cuore. © 2018. See: http://www.tran- scrime.it/wp-content/uploads/2018/12/MORE_FinalReport.pdf 23 See: https://www.irishtimes.com/opinion/editorial/the-irish-times-view-on-organised-crime-taking-on-the-gangs-1.4478269 24 See: https://www.rte.ie/news/crime/2019/1222/1102668-crime/ 25 See: was https://www.osac.gov/Country/Ireland/Content/Detail/Report/ddd81b65-864e-4b6c-9f3c-18571e1f0705 26 See: https://www.cia.gov/library/publications/the-world-factbook/geos/ei.html 27 See: https://www.rte.ie/news/crime/2019/1222/1102668-crime/ 28 See: http://www.emcdda.europa.eu/countries/drug-reports/2019/ireland/drug-use_en 29 See: http://www.emcdda.europa.eu/countries/drug-reports/2019/ireland/drug-use_en 30 See: https://ourworldindata.org/illicit-drug-use 31 See: https://www.cso.ie/en/releasesandpublications/ep/p-rc/recordedcrimeq12020/ 32 See: https://www.theglobaleconomy.com/indi_menu.php?page_url=rankings&indicator=theft&type=0&withDataFor= 33 See: https://www.refworld.org/docid/5b3e0a36a.html 34 See: https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report-Complete-062420-FINAL.pdf 35 See: https://www.globalslaveryindex.org/2018/fndings/regional-analysis/europe-and-central-asia/ 36 See: https://www.socialistsanddemocrats.eu/sites/default/fles/2019-01/the_european_tax_gap_en_190123.pdf 37 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf

Ireland - Threat Assessment - 2021 Page 42 of 45 38 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 39 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 40 See: http://www.justice.ie/en/JELR/National_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf/Files/Nation- al_Risk_Assessment_Money_Laundering_and_Terrorist_Financing_Oct16.pdf 41 See: https://www.pwc.ie/reports/irish-economic-crime-survey-2018.html 42 See: https://www.pwc.ie/survey/2016-economic-crime-survey.html 43 See: https://www.matheson.com/news-and-insights/article/anti-money-laundering-a-2019-perspective 44 See: https://www.cso.ie/en/releasesandpublications/ep/p-rc/recordedcrimeq12020/ 45 See: https://www.cso.ie/en/releasesandpublications/ep/p-rc/recordedcrimeq42017/ 46 See: https://www.theglobaleconomy.com/indi_menu.php?page_url=rankings&indicator=theft&type=0&withDataFor= 47 See: http://www3.weforum.org/docs/WEF_TheGlobalCompetitivenessReport2019.pdf 48 See: https://www.pwc.ie/reports/irish-economic-crime-survey-2018.html 49 See: https://www.justice-ni.gov.uk/sites/default/fles/publications/justice/cross-border-organised-crime-assessment-2018.PDF 50 See: https://www.jbs.cam.ac.uk/fleadmin/user_upload/research/centres/alternative-fnance/downloads/2018-12-ccaf-2nd-global- cryptoasset-benchmarking.pdf 51 See: https://think.ing.com/reports/cracking-the-code-on-cryptocurrency/ 52 See: http://www.cab.ie/en/CAB/CAB%20Annual%20Report%202018%20-%20Reduced.pdf/Files/ CAB%20Annual%20Report%202018%20-%20Reduced.pdf 53 See: https://www.thelocal.it/20200915/the-recovery-fund-is-in-their-sights-europol-warns-eu-countries-of-mafa-profting-from- covid-19-crisis 54 See: https://sanctionsguide.eversheds-sutherland.com/countries/ireland/ 55 See: https://www.independent.ie/business/farming/beef/ireland-is-anxious-to-trade-with-iran-but-there-are-issues- creed-37957122.html 56 See: https://www.cso.ie/en/media/csoie/releasespublications/documents/externaltrade/2019/trade_october2019.pdf 57 See: https://www.tehrantimes.com/news/423916/Trade-between-Iran-Ireland-doubles-in-2017 58 See: https://embassy-fnder.com/ireland_embassies 59 See: https://www.treasury.gov/ofac/downloads/ctrylst.txt; and See: https://sanctionssearch.ofac.treas.gov 60 See: https://isis-online.org/ppi/detail/peddling-peril-index-for-2019 61 See: https://www.fatf-gaf.org/media/fatf/documents/reports/mer4/MER-Ireland-2017.pdf 62 See: https://visionofhumanity.org/wp-content/uploads/2020/11/GTI-2020-web-1.pdf 63 See: https://merrionstreet.ie/en/News-Room/20190804_National_Risk_Assessment.pdf 64 See: https://www.mi5.gov.uk/northern-ireland 65 See: Ernesto U. Savona and Michele Riccardi (eds), 2018, Mapping the risk of Serious and Organised Crime infltration in European Businesses – Final report of the MORE Project Milano: Transcrime – Università Cattolica del Sacro Cuore. © 2018. See: http://www.tran- scrime.it/wp-content/uploads/2018/12/MORE_FinalReport.pdf 66 See: Ernesto U. Savona and Michele Riccardi (eds), 2018, Mapping the risk of Serious and Organised Crime infltration in European Businesses – Final report of the MORE Project Milano: Transcrime – Università Cattolica del Sacro Cuore. © 2018. See: http://www.tran- scrime.it/wp-content/uploads/2018/12/MORE_FinalReport.pdf 67 See: Ernesto U. Savona and Michele Riccardi (eds), 2018, Mapping the risk of Serious and Organised Crime infltration in European Businesses – Final report of the MORE Project Milano: Transcrime – Università Cattolica del Sacro Cuore. © 2018. See: http://www.tran- scrime.it/wp-content/uploads/2018/12/MORE_FinalReport.pdf 68 See: https://gfntegrity.org/gftrade/ 69 See: https://www.cia.gov/library/publications/the-world-factbook/geos/ei.html 70 See: https://www.fatf-gaf.org/media/fatf/documents/reports/mer4/MER-Ireland-2017.pdf 71 See: http://www.fatf-gaf.org/media/fatf/documents/reports/mer4/Follow-Up-Report-Ireland-2019.pdf 72 See: https://www.openownership.org/map/#IT 73 See: https://www.u4.no/publications/professional-enablers-of-economic-crime-during-crises 74 See: http://www.oecd.org/tax/transparency/documents/exchange-of-information-on-request-ratings.htm 75 See: https://www.theglobaleconomy.com/rankings/wb_regulatory_quality/#Italy 76 See: https://www.centralbank.ie/regulation/anti-money-laundering-and-countering-the-fnancing-of-terrorism/legislation

Ireland - Threat Assessment - 2021 Page 43 of 45 77 See: https://www.bankingsupervision.europa.eu/press/pr/date/2018/html/ssm.pr181214.en.html 78 See: https://www.centralbank.ie/docs/default-source/publications/fnancial-stability-review/fnancial-stability-review-2019-i/fnancial- stability-review-2019-i.pdf?sfvrsn=9 79 See: https://www.irishexaminer.com/news/arid-30896655.html 80 See: https://www.europarl.europa.eu/RegData/etudes/STUD/2017/598603/EPRS_STU%282017%29598603_EN.pdf 81 See: https://www.europol.europa.eu/publications-documents/suspicion-to-action-converting-fnancial-intelligence-greater-operation- al-impact 82 See: https://ec.europa.eu/eurostat/statistics-explained/index.php/Government_expenditure_on_public_order_and_safety#Expendit- ure_on_.27public_order_and_safety.27 83 See: http://www.justice.ie/en/JELR/Pages/PR17000324 84 See: http://www3.weforum.org/docs/WEF_TheGlobalCompetitivenessReport2019.pdf 85 See: https://ourworldindata.org/grapher/prison-population-rate? tab=table&time=2018&country=USA~DEU~England%20and%20Wales~FRA~PRT~BRA~JPN~IDN~AUT~AUS~ITA~IND 86 See: https://www.prisonstudies.org/country/ireland-republic 87 See: https://www.irishprisons.ie/wp-content/uploads/documents_pdf/OFFENCE-GROUP-Year-2007-to-Year-2019.pdf 88 See: https://www.osac.gov/Country/Ireland/Content/Detail/Report/ddd81b65-864e-4b6c-9f3c-18571e1f0705 89 See: http://www.justice.ie/en/JELR/Pages/An_Garda_Siochana_facts_and_fgures 90 See: https://www.state.gov/wp-content/uploads/2020/06/2020-TIP-Report-Complete-062420-FINAL.pdf 91 See: https://www.globalslaveryindex.org/2018/fndings/regional-analysis/europe-and-central-asia/ 92 See: https://www.rte.ie/news/crime/2019/1222/1102668-crime/ 93 See: https://freedomhouse.org/report/countries-world-freedom-2019 94 See: https://www.heritage.org/index/ranking 95 See: https://baselgovernance.org/sites/default/fles/2019-08/Basel%20AML%20Index%202019.pdf 96 See: https://www.globalslaveryindex.org/2018/fndings/regional-analysis/europe-and-central-asia/ 97 See: http://www.oecd.org/tax/transparency/documents/exchange-of-information-on-request-ratings.htm 98 See: https://www.itu.int/dms_pub/itu-d/opb/str/D-STR-GCI.01-2018-PDF-E.pdf 99 See: http://www.oecd.org/daf/anti-bribery/OECD-Anti-Bribery-Convention-Enforcement-Data-2020.pdf 100 See: https://www.transparency.org/en/exporting-corruption 101 See: https://ec.europa.eu/fnance/docs/law/200507-anti-money-laundering-terrorism-fnancing-action-plan_en.pdf 102 See: https://ec.europa.eu/info/fles/200507-anti-money-laundering-terrorism-fnancing-action-plan-factsheet_en 103 See: https://www.ebf.eu/wp-content/uploads/2020/03/EBF-Blueprint-for-an-effective-EU-framework-to-fght-money-laundering-Lift- ing-the-Spell-of-Dirty-Money-.pdf 104 See: https://www.ceps.eu/wp-content/uploads/2021/01/TFR_Anti-Money-Laundering-in-the-EU.pdf 105 See: https://www.fatf-gaf.org/media/fatf/documents/reports/mer4/MER-Ireland-2017.pdf 106 See: http://www.fatf-gaf.org/media/fatf/documents/reports/mer4/Follow-Up-Report-Ireland-2019.pdf 107 See: https://www.knomad.org/data/remittances?tid%5B146%5D=146 108 See: https://www.knomad.org/data/remittances?tid%5B146%5D=146

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