and effective and embedded risk management. these are critical enablers for credit unions to address the challenges they face and avail of development opportunities. responsibility for meeting these challenges rests first and foremost with the board of each credit union, although there remains a need for greater sectoral leadership too. each board must set and own the strategic plan for its credit union. the strategy should be clear in identifying and setting out actions to address current and emerging sustainability challenges. individually and collectively, credit unions need to form and realise a clear vision of their role in the provision of financial services and ensure that they can implement the necessary business model and technological changes to realise their vision and fulfil this role for their members in a safe and sustainable way. strategic plans need to be tailored to the credit union ’ s individual financial circumstances and capabilities, as well as common bond dynamics, while addressing operational and commercial challenges. strategic plans should demonstrate sound and prudent risk - focused strategy formulation, business planning and implementation, aimed at the sustainable delivery of member products and services. post restructuring development the sector has undergone significant restructuring in recent years. restructuring provides strategic transfer solutions for weaker credit unions, enabling affected members to retain access 5 / 7 bis central bankers'speeches to credit union services and indeed gain access to a wider range of services provided by stronger, larger credit unions. restructuring also offers opportunities for other credit unions to build scale and reach by coming together voluntarily. this restructuring has resulted in a significant change in the asset size profile of the sector. at 30 september 2021 there were 213 trading credit unions ; down from 343 at 30 september 2015. credit unions with assets of at least €100 million now represent 67 per cent of total sector assets – up from 41 percent in 2015. at the other end of the size scale credit union with assets of less than €40 million now represent 10 percent of total sector assets. central bank strategy the central bank published its new strategy yesterday9, 5th november. as key central bank stakeholders, i recommend you take the time to read the short strategy document, which sets out the four core key themes underpinning the strategy. these themes will be our “ north star ” when it comes to our focus in the years ahead and will act as a constant guide to everything we do as an organisation : future - focused – the world in which we operate is changing rapidly. the economy, the financial system and financial services and products are changing and will continue to change over the coming years. we want to be ready

lending. in 2018, to facilitate increased diversification, we introduced additional classes of investment in which credit unions may invest surplus funds. while development of appropriate investment structures for some of these new classes has taken time, recent developments will facilitate investment in approved housing bodies and corporate bonds for those credit unions seeking to do so. in 2020, we introduced changes to the lending framework providing those credit unions with the financial strength, competence and capability, flexibility to undertake increased longer term lending, including home mortgage and business lending. after this period of significant change, the central bank is not planning further significant changes to the specific regulations directly focused on the credit union sector in the foreseeable future. that is not to say we are closed to the possibility of future changes, and we will continue to engage with sector representatives and the oireachtas on the appropriateness and effectiveness of the credit union regulatory framework. notwithstanding this degree of relative stability, credit union boards and management will have to continue to address regulatory and legislative change relevant to the financial services system as a whole. one such area where there is increasing scrutiny relates to aml / ctf, as recognised by the theme of this event. at an international level, shortcomings in the aml and ctf frameworks and approaches have been recognised and we can, consequently, expect changes to underlying regulations and the supervision of aml and ctf matters. it is vitally important that ireland, as a small, open economy with a thriving financial services industry, is pro - active in preventing its financial system from being used for money laundering and terrorist financing purposes. all financial service providers, including credit unions, have an important role in achieving this. the central bank is the competent authority for aml / cft supervision of credit unions. 4 this requires us to effectively monitor credit unions ’ compliance with their legislative obligations and, where weaknesses are identified, to take actions that are reasonably necessary and 3 / 7 bis central bankers'speeches proportionate to ensure compliance. in delivering on this mandate, in september 2019 the central bank published aml / cft guidelines for the financial sector, 5 which were subsequently revised in june 2021 to reflect changes in the legislation. the purpose of these guidelines is to provide clarity on the central bank ’ s expectations in respect of compliance with aml / cft obligations as set out in : the criminal justice act 2010 ; central bank aml / cft sectoral reports / bulletins ; and relevant european supervisory authority guidelines. areas of focus