{"id":20086,"date":"2022-11-06T20:13:12","date_gmt":"2022-11-06T20:13:12","guid":{"rendered":"https:\/\/legalblog.ie\/?p=20086"},"modified":"2024-03-24T23:47:53","modified_gmt":"2024-03-24T23:47:53","slug":"aml-customer-risk","status":"publish","type":"post","link":"https:\/\/legalblog.ie\/aml-customer-risk\/","title":{"rendered":"AML Risk Factors"},"content":{"rendered":"<div id=\"ez-toc-container\" class=\"ez-toc-v2_0_63 counter-hierarchy ez-toc-counter ez-toc-grey ez-toc-container-direction\">\n<div class=\"ez-toc-title-container\">\n<p class=\"ez-toc-title \" >Table of Contents<\/p>\n<span class=\"ez-toc-title-toggle\"><a href=\"#\" class=\"ez-toc-pull-right ez-toc-btn ez-toc-btn-xs ez-toc-btn-default ez-toc-toggle\" aria-label=\"Toggle Table of Content\"><span class=\"ez-toc-js-icon-con\"><span class=\"\"><span class=\"eztoc-hide\" style=\"display:none;\">Toggle<\/span><span class=\"ez-toc-icon-toggle-span\"><svg style=\"fill: #999;color:#999\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\" class=\"list-377408\" width=\"20px\" height=\"20px\" viewBox=\"0 0 24 24\" fill=\"none\"><path d=\"M6 6H4v2h2V6zm14 0H8v2h12V6zM4 11h2v2H4v-2zm16 0H8v2h12v-2zM4 16h2v2H4v-2zm16 0H8v2h12v-2z\" fill=\"currentColor\"><\/path><\/svg><svg style=\"fill: #999;color:#999\" class=\"arrow-unsorted-368013\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\" width=\"10px\" height=\"10px\" viewBox=\"0 0 24 24\" version=\"1.2\" baseProfile=\"tiny\"><path d=\"M18.2 9.3l-6.2-6.3-6.2 6.3c-.2.2-.3.4-.3.7s.1.5.3.7c.2.2.4.3.7.3h11c.3 0 .5-.1.7-.3.2-.2.3-.5.3-.7s-.1-.5-.3-.7zM5.8 14.7l6.2 6.3 6.2-6.3c.2-.2.3-.5.3-.7s-.1-.5-.3-.7c-.2-.2-.4-.3-.7-.3h-11c-.3 0-.5.1-.7.3-.2.2-.3.5-.3.7s.1.5.3.7z\"\/><\/svg><\/span><\/span><\/span><\/a><\/span><\/div>\n<nav><ul class='ez-toc-list ez-toc-list-level-1 ' ><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-1\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Risk_Levels\" title=\"Risk Levels\">Risk Levels<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-2\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Policies_and_Procedures\" title=\"Policies and Procedures\">Policies and Procedures<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-3\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Simplified_Due_Diligence\" title=\"Simplified Due Diligence\">Simplified Due Diligence<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-4\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Standard_Due_Diligence\" title=\"Standard Due Diligence\">Standard Due Diligence<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-5\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Obtaining_Information\" title=\"Obtaining Information\">Obtaining Information<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-6\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Identifying_High_Risk_Cases\" title=\"Identifying High Risk Cases\">Identifying High Risk Cases<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-7\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Enhanced_Due_Diligence\" title=\"Enhanced Due Diligence\">Enhanced Due Diligence<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-8\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#PEPs\" title=\"PEPs\">PEPs<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-9\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Close_Associates\" title=\"Close Associates\">Close Associates<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-10\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#Scope_of_PEP\" title=\"Scope of PEP\">Scope of PEP<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-3'><a class=\"ez-toc-link ez-toc-heading-11\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/#PEP_Action\" title=\"PEP Action\">PEP Action<\/a><ul class='ez-toc-list-level-4' ><li class='ez-toc-heading-level-4'><a class=\"ez-toc-link ez-toc-heading-12\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/2\/#Non-exhaustive_list_of_factors_suggesting_potentially_lower_risk\" title=\"Non-exhaustive list of factors suggesting potentially lower risk\">Non-exhaustive list of factors suggesting potentially lower risk<\/a><\/li><li class='ez-toc-page-1 ez-toc-heading-level-4'><a class=\"ez-toc-link ez-toc-heading-13\" href=\"https:\/\/legalblog.ie\/aml-customer-risk\/2\/#Non-exhaustive_list_of_factors_suggesting_potentially_higher_risk\" title=\"Non-exhaustive list of factors suggesting potentially higher risk\">Non-exhaustive list of factors suggesting potentially higher risk<\/a><\/li><\/ul><\/li><\/ul><\/nav><\/div>\n<h3><span class=\"ez-toc-section\" id=\"Risk_Levels\"><\/span>Risk Levels<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>The legislation contemplates three levels of customer due diligence reflecting the risk-based approach;<\/p>\n<ul>\n<li>standard customer diligence<\/li>\n<li>simplified customer due diligence and<\/li>\n<li>enhanced customer due diligence.<\/li>\n<\/ul>\n<p>Businesses covered by money-laundering legislation may take the identification and other obligations applicable in a manner and to such extent as reasonably warranted by the lower risks involved in relation to a business relationship or transaction where it identifies in the risk assessment an area of lower risk into which the relationship or transaction falls and considers that the relationship or transaction presents a lower risk. The general criteria for assessing risk applies.<\/p>\n<p>A business relationship or transaction may be considered to present a lower degree of risk if a reasonable person having regard to the relevant criteria would determine that the relationship or transaction presents a lower risk of money laundering or terrorist financing.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Policies_and_Procedures\"><\/span>Policies and Procedures<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Businesses subject to money-laundering obligations are obliged to have certain written policies and procedures under that legislation. They must examine the background and purpose of all transactions that are<\/p>\n<ul>\n<li>complex<\/li>\n<li>unusually large<\/li>\n<li>conducted in an unusual pattern<\/li>\n<li>does not have an apparent economic a lawful purpose.<\/li>\n<\/ul>\n<p>They must increase the degree and nature of monitoring of a business relationship in order to determine whether such transactions appear suspicious. Failure to do so is subject to the same sanctions as a breach of the general money-laundering obligations.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Simplified_Due_Diligence\"><\/span>Simplified Due Diligence<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Simplified customer due diligence allows reduced due diligence in such cases where the money laundering\/terrorist financing risk is relatively low.<\/p>\n<p>Designated businesses may \u00a0apply simplified customer due diligence- that is, applying customer due diligence measures in such manner, to such extent and at such times as is reasonably warranted by the lower risk of money laundering or terrorist financing.<\/p>\n<p>Simplified customer due diligence can only be applied where a designated business has identified an area of lower risk in its business risk assessment, the business relationship or transaction falls into that area, and the relationship or transaction concerned can reasonably be considered, having regard to certain matters, to be low risk. Where this \u00a0is applied, the reasons for its application and the evidence on which it was based must be recorded, and the business relationship and transactions concerned must be monitored.<\/p>\n<p>Where simplified due diligence measures are applied a record must be kept of the reasons for so deciding and the evidence on which it was based. The person or entity must carry out sufficient monitoring of the transactions and business relationships to enable it to detect unusual or suspicious transactions. Additional criteria may be prescribed by regulations.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Standard_Due_Diligence\"><\/span>Standard Due Diligence<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Standard due diligence requires the relevant entities subject to the legislation to identify their customers and verify the identity of customers\u2019 beneficial owners on a risk-based approach. They must identify them and obtain information on the purpose and intended nature of the business concerned. See the other Chapters.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Obtaining_Information\"><\/span>Obtaining Information<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Businesses covered by money-laundering obligations must obtain information reasonably warranted by the risk of money-laundering or terrorist financing,on the purpose and intended nature of the business relationship prior to establishing that business relationship.<\/p>\n<p>Where it is unable to do so, it must not provide the service for as long as that failure continues. It must monitor any business relationship with the customer to the extent reasonably warranted by the risk of money-laundering or terrorist financing.<\/p>\n<p>Before establishing a business relationship with a customer which is subject to obligations to disclose beneficial ownership under EU legislation, the service provider must ascertain that the information concerning beneficial ownership is entered on the beneficial ownership register provided for under the legislation.This applies to the legislation regarding beneficial ownership of trusts and companies.<\/p>\n<p>A financial institution or credit institution may allow an account to be opened but may not carry out transactions until it has done so.<\/p>\n<p>A breach of the above obligations is subject to the same sanctions as a breach of the general money-laundering obligations.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Identifying_High_Risk_Cases\"><\/span>Identifying High Risk Cases<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Where the customer is from certain prescribed places, certain other provisions apply, or there are obligations to apply enhanced due diligence obligations that mentioned next.\u00a0 Enhanced due diligence obligations apply in relation to so-called politically exposed persons.<\/p>\n<p>A designated business is to take steps to determine whether or not a customer, or a beneficial owner connected with a customer or service concerned, is a politically exposed person or an immediate family member, or a close associate of a politically exposed person.<\/p>\n<p>Steps must be taken before establishing a business relationship or carrying out a transaction.\u00a0 Steps to be taken are such steps as are reasonably warranted by the risk that the customer or beneficial owner is involved in money laundering or terrorist financing.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Enhanced_Due_Diligence\"><\/span>Enhanced Due Diligence<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Enhanced due diligence provides for more onerous requirements for customers and businesses who appear to present a higher risk.<\/p>\n<p>A \u00a0designated business is to apply enhanced customer due diligence measures when dealing with a customer established or residing in a high-risk third country. There is an exception that applies when the customer is a branch or majority-owned subsidiary of a designated business established in the European Union which complies with the group\u2019s group-wide policies and procedures. These cases must be dealt with using a risk-based approach.<\/p>\n<p>A designated business must apply enhanced customer due diligence measures where a business relationship or transaction presents a higher degree of risk. This is to be applied where the relationship or transaction concerned can reasonably be considered, having regard to certain matters, to be high risk. The Minister may prescribe a factor that is suggestive of high risk and that must be taken into account by designated businesses.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"PEPs\"><\/span>PEPs<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Enhanced customer due diligence applies to politically exposed persons. A politically exposed person is an individual who is or has, within the previous 12 months, been entrusted with a prominent public position, including<\/p>\n<ul>\n<li>certain designated officials<\/li>\n<li>politicians<\/li>\n<li>managers of state-owned enterprise and<\/li>\n<li>certain other prescribed individuals.<\/li>\n<\/ul>\n<p>They include members of the government Parliament governing bodies of a political party, judges, Central bank auditors\u2019 ambassadors and persons involved in certain international organisations.<\/p>\n<h3><span class=\"ez-toc-section\" id=\"Close_Associates\"><\/span>Close Associates<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>Close associates include those with close and connected business interests or trustees or hold assets for the benefit of the person concerned. Immediate family members include spouses, children parents thousands of children and other classes of person.<\/p>\n<p>Where a customer or beneficial owner is a politically exposed person or a family member or close associate the designated institution must take steps to determine the source or funds or wealth.<\/p>\n<p>Where it cannot be produced, the designated person cannot continue the relationship. They must obtain senior management approval for an ongoing business relationship.<\/p>\n<p>A close associate is<\/p>\n<ul>\n<li>an individual who is a joint beneficial owner of a legal entity arrangement or a close business relation of the politically exposed person.<\/li>\n<li>anyone who has sole beneficial ownership of a legal entity or a legal arrangements setup for the actual benefit of the PEP.<\/li>\n<li>an immediate family member, spouse, partner, co-habitant child or spouses of children or equivalent.<\/li>\n<\/ul>\n<h3><span class=\"ez-toc-section\" id=\"Scope_of_PEP\"><\/span>Scope of PEP<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>A politically exposed person is an individual who has at any time in the preceding 12 months been entrusted with a prominent public function, including<\/p>\n<ul>\n<li>specified officials,<\/li>\n<li>members of the administrative, management and supervisory body of state-owned enterprises.<\/li>\n<\/ul>\n<p>A specified individual means any head of State, government, government Minister; a Member of Parliament; senior judge ambassador or high-ranking officer in the army, charg\u00e9 d\u2019affair.<\/p>\n<p>Immediate family members include spouses, an equivalent of spouses, children, spouses of children, parent and other family members who are prescribed.<\/p>\n<p>A designated entity is deemed to know that another is a politically exposed person or is an immediate family member on the basis of<\/p>\n<ul>\n<li>information in its possession,<\/li>\n<li>in cases where the designated business has contravened the requirements, \u00a0information that would have otherwise come into his possession<\/li>\n<li>or public knowledge, and<\/li>\n<\/ul>\n<p>on the basis of the above, that there are reasonable grounds for concluding that the designated business so knows<\/p>\n<h3><span class=\"ez-toc-section\" id=\"PEP_Action\"><\/span>PEP Action<span class=\"ez-toc-section-end\"><\/span><\/h3>\n<p>If a designated business knows or has reasonable grounds to believe a customer residing outside the State is or has become politically exposed, an immediate family member or close associate of a politically exposed person, they shall ensure that<\/p>\n<ul>\n<li>approval is obtained from senior management of the designated business before the business relationship is established or continued;<\/li>\n<li>determine the source of wealth and all funds for the following transactions:\n<ul>\n<li>transactions the subject of a business relationship with the customer that is carried out with the customer in respect of which the service is sought, or<\/li>\n<li>occasional transactions carried out on behalf of the customer and<\/li>\n<\/ul>\n<\/li>\n<li>they apply such additional measures in the course of monitoring the business relationship, including monitoring the source of wealth and funds;<\/li>\n<li>that the business it is warranted by the risk of money laundering or terrorist financing.<\/li>\n<\/ul>\n<p>If a designated business is unable to apply the measures, it must discontinue the business relationship or not provide services.<\/p>\n<p><!--nextpage--><\/p>\n<p>F208[SCHEDULE 3<\/p>\n<h4>Non-exhaustive list of factors suggesting potentially lower risk<\/h4>\n<p>Section 34A<\/p>\n<p>(1) Customer risk factors:<\/p>\n<p>(a) public companies listed on a stock exchange and subject to disclosure requirements (either by stock exchange rules or through law or enforceable means), which impose requirements to ensure adequate transparency of beneficial ownership;<\/p>\n<p>(b) public administrations or enterprises;<\/p>\n<p>(c) customers that are resident in geographical areas of lower risk as set out in subparagraph (3).<\/p>\n<p>(2) Product, service, transaction or delivery channel risk factors:<\/p>\n<p>(a) life assurance policies for which the premium is low;<\/p>\n<p>(b) insurance policies for pension schemes if there is no early surrender option and the policy cannot be used as collateral;<\/p>\n<p>(c) a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by way of deduction from wages, and the scheme rules do not permit the assignment of a member\u2019s interest under the scheme;<\/p>\n<p>(d) financial products or services that provide appropriately defined and limited services to certain types of customers, so as to increase access for financial inclusion purposes;<\/p>\n<p>(e) products where the risks of money laundering and terrorist financing are managed by other factors such as purse limits or transparency of ownership (e.g. certain types of electronic money).<\/p>\n<p>(3) F209[Geographical risk factors &#8211; registration, establishment, residence in:]<\/p>\n<p>(a) Member States;<\/p>\n<p>(b) third countries having effective anti-money laundering (AML) or combating financing of terrorism (CFT) systems;<\/p>\n<p>(c) third countries identified by credible sources as having a low level of corruption or other criminal activity;<\/p>\n<p>(d) third countries which, on the basis of credible sources such as mutual evaluations, detailed assessment reports or published follow-up reports, have requirements to combat money laundering and terrorist financing consistent with the revised Financial Action Task Force (FATF) recommendations and effectively implement these requirements.]<\/p>\n<p>Annotations<\/p>\n<p>Amendments:<\/p>\n<p>F208<br \/>\nInserted (26.11.2018) by Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 (26\/2018), s. 38, S.I. No. 486 of 2018.<\/p>\n<p>F209<br \/>\nSubstituted (23.04.2021) by Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 (3\/2021), s. 27, S.I. No. 188 of 2021.<\/p>\n<p>F210[SCHEDULE 4<\/p>\n<h4>Non-exhaustive list of factors suggesting potentially higher risk<\/h4>\n<p>Section 39<\/p>\n<p>(1) Customer risk factors:<\/p>\n<p>(a) the business relationship is conducted in unusual circumstances;<\/p>\n<p>(b) customers that are resident in geographical areas of higher risk as set out in subparagraph (3);<\/p>\n<p>(c) non-resident customers;<\/p>\n<p>(d) legal persons or arrangements that are personal asset-holding vehicles;<\/p>\n<p>(e) companies that have nominee shareholders or shares in bearer form;<\/p>\n<p>(f) businesses that are cash intensive;<\/p>\n<p>(g) the ownership structure of the company appears unusual or excessively complex given the nature of the company\u2019s F211[business;]<\/p>\n<p>F212[(h) the customer is a third country national who applies for residence rights or citizenship in the State in exchange for capital transfers, purchase of property or government bonds or investment in corporate entities in the State.]<\/p>\n<p>(2) Product, service, transaction or delivery channel risk factors:<\/p>\n<p>(a) private banking;<\/p>\n<p>(b) products or transactions that might favour anonymity;<\/p>\n<p>F211[(c) non face-to-face business relationships or transactions, without certain safeguards, such as electronic identification means, relevant trust services as defined in the Electronic Identification Regulation or any other secure, remote or electronic, identification process regulated, recognised, approved or accepted by the relevant national authorities;]<\/p>\n<p>(d) payment received from unknown or unassociated third parties;<\/p>\n<p>(e) new products and new business practices, including new delivery mechanism, and the use of new or developing technologies for both new and pre-existing F211[products;]<\/p>\n<p>F212[(f) transactions related to oil, arms, precious metals, tobacco products, cultural artefacts and other items of archaeological, historical, cultural and religious importance, or of rare or scientific value, as well as ivory and protected species.]<\/p>\n<p>(3) Geographical risk factors:<\/p>\n<p>(a) countries identified by credible sources, such as mutual evaluations, detailed assessment reports or published follow-up reports, as not having effective AML\/CFT systems;<\/p>\n<p>(b) countries identified by credible sources as having significant levels of corruption or other criminal activity;<\/p>\n<p>(c) countries subject to sanctions, embargos or similar measures issued by organisations such as, for example, the European Union or the United Nations;<\/p>\n<p>(d) countries (or geographical areas) providing funding or support for terrorist activities, or that have designated terrorist organisations operating within their country.]<\/p>\n<p>Annotations<\/p>\n<p>Amendments:<\/p>\n<p>F210<br \/>\nInserted (26.11.2018) by Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 (26\/2018), s. 39, S.I. No. 486 of 2018.<\/p>\n<p>F211<br \/>\nSubstituted (23.04.2021) by Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 (3\/2021), s. 28(a)(i), (b)(i), b(ii), S.I. No. 188 of 2021.<\/p>\n<p>F212<br \/>\nInserted (23.04.2021) by Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 (3\/2021), s. 28(a)(ii), (b)(iii), S.I. No. 188 of 2021.<\/p>\n<p>&nbsp;<\/p>\n<!--themify_builder_content-->\n<div id=\"themify_builder_content-20086\" data-postid=\"20086\" class=\"themify_builder_content themify_builder_content-20086 themify_builder tf_clear\">\n    <\/div>\n<!--\/themify_builder_content-->\n","protected":false},"excerpt":{"rendered":"<p>Risk Levels The legislation contemplates three levels of customer due diligence reflecting the risk-based approach; standard customer diligence simplified customer due diligence and enhanced customer due diligence. Businesses covered by money-laundering legislation may take the identification and other obligations applicable in a manner and to such extent as reasonably warranted by the lower risks involved [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_exactmetrics_skip_tracking":false,"_exactmetrics_sitenote_active":false,"_exactmetrics_sitenote_note":"","_exactmetrics_sitenote_category":0,"footnotes":""},"categories":[291],"tags":[],"_links":{"self":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/20086"}],"collection":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/comments?post=20086"}],"version-history":[{"count":9,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/20086\/revisions"}],"predecessor-version":[{"id":34099,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/posts\/20086\/revisions\/34099"}],"wp:attachment":[{"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/media?parent=20086"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/categories?post=20086"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/legalblog.ie\/wp-json\/wp\/v2\/tags?post=20086"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}