Ann: Central Bank of Ireland correspondence, page-147

I might be baggying out here, but the more I look into past actions taken by the Central Bank of Ireland in respect to AML breaches, the less concerned I become.

This hasn't been an exhaustive deep dive by any means, but I'm yet to find evidence of an organisation having its license stripped away as a result of regulatory action. Even the fines applied for breaches don't seem to be anywhere near as damaging as some of the stuff we've seen locally (i.e. Westpac's $1.3b slap in recent times).

For example, here's a €2.2m fine for the Allied Irish Banks (a seemingly large entity, with 11,000 employees), for "significant failures in AIB’santi-money laundering and counter terrorist financing controls, policies and procedures".

Here's another one for Ulster bank, fined €3.2m, which was at the time (and maybe still?) the biggest ever issued by the Central Bank for breaches of the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010.

The market has reacted violently to language and context in today's announcement. Management certainly hasn't held back or attempted to provide any positive spin on the situation, which is almost a little odd. It almost feels like there's an element of using really forceful language to show contrition, prior to the formal response being lodged.

I've held this one for almost 7 years now. I suspect today might look like a significant buying opportunity in hindsight, but it's very hard to know for sure simply based on the details we have been provided to date. I'll await further update before doing anything.