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Ireland - AML/CFT and Sanctions

Module Application

Anti-money laundering, countering the financing of terrorism and sanctions compliance are core components of Ireland's financial crime prevention framework and are subject to extensive statutory, regulatory and supervisory oversight at Irish, European Union and international level. This module applies to organisations within scope of the Irish AML/CFT regime, including designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, and to organisations that must comply with applicable EU and Irish sanctions measures when conducting business in or from Ireland.

Organisations operating in this area are held to high standards by regulators, competent authorities and law enforcement bodies including the Central Bank of Ireland, Financial Intelligence Unit Ireland, An Garda Siochana, the Revenue Commissioners, the Companies Registration Office and relevant EU institutions and authorities. These bodies require organisations to demonstrate a documented risk-based approach, effective governance and senior management oversight, robust customer due diligence and beneficial ownership controls, timely suspicious transaction and activity reporting, sanctions screening and asset-freezing controls, and adequate training, recordkeeping and assurance arrangements.

To meet these expectations, organisations must understand whether they are in scope, maintain AML/CFT and sanctions policies, controls and procedures proportionate to their risk profile, assess business-wide and customer-level risk, identify and verify customers and beneficial owners, conduct enhanced due diligence where risk is elevated, monitor transactions and relationships, escalate and report suspicions, and preserve evidence of compliance. This module is designed to support organisations in navigating Ireland's AML/CFT and sanctions regulatory landscape, providing a structured framework to assess, implement and maintain compliance while supporting market integrity, crime prevention and the protection of the financial system.

Module Scope

This module covers the principal legal framework, governance, business risk assessment, customer due diligence, enhanced due diligence, ongoing monitoring, suspicious reporting, sanctions, training, recordkeeping, audit and enforcement obligations applicable to AML/CFT and sanctions compliance in Ireland. It addresses the obligations of designated persons, the role of senior management, the design and approval of policies, controls and procedures, and the practical operation of risk-based controls across onboarding, relationship management, transaction monitoring and escalation.

The scope further includes beneficial ownership transparency, politically exposed persons, high-risk jurisdictions, correspondent and other higher-risk relationships, technology and emerging risk controls, cryptoasset-related obligations where relevant, EU and UN sanctions compliance, asset-freezing and reporting expectations, regulatory engagement and the consequences that may arise where organisations fail to meet applicable AML/CFT or sanctions standards.

Some of the specific questions this module covers are:

  • Does the organisation determine whether it is a designated person under the Irish AML/CFT framework and identify the EU and Irish sanctions requirements that apply to its activities, customers and business relationships?
  • Does the organisation maintain senior management oversight, documented policies, controls and procedures, and clear accountability for AML/CFT and sanctions compliance?
  • Does the organisation conduct and maintain a business-wide risk assessment that identifies, assesses and manages money laundering, terrorist financing, sanctions and proliferation financing risks?
  • Does the organisation apply customer due diligence measures to identify and verify customers and beneficial owners, understand the purpose and intended nature of relationships, and assess customer risk?
  • Does the organisation apply enhanced due diligence in higher-risk situations, including PEPs, high-risk third countries, unusual transactions, complex structures, and other elevated-risk relationships?
  • Does the organisation monitor relationships and transactions on an ongoing basis, keep customer and risk information up to date, and investigate unusual or suspicious activity?
  • Does the organisation identify, escalate and report suspicious transactions or activity to the appropriate authorities while complying with tipping-off and confidentiality restrictions?
  • Does the organisation maintain effective sanctions screening, asset-freezing, reporting, training, recordkeeping and assurance controls to prevent breaches and evidence compliance?

The key topics covered in this module are:

  • Legal Framework and Governance
  • Business Risk Assessment
  • Customer Due Diligence
  • Enhanced Due Diligence
  • Ongoing Monitoring and Transaction Scrutiny
  • Suspicious Transaction and Activity Reporting
  • Sanctions and Restrictive Measures
  • Beneficial Ownership Transparency
  • Cryptoassets and Transfers of Funds
  • Training, Recordkeeping and Audit
  • Regulatory Engagement, Enforcement and Consequences

The module encompasses a range of legislative sources including:

  • Criminal Justice (Money Laundering and Terrorist Financing) Act 2010
  • Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018
  • Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021
  • Criminal Justice (Terrorist Offences) Act 2005
  • Central Bank Act 1942 
  • Central Bank Reform Act 2010
  • Central Bank (Supervision and Enforcement) Act 2013
  • European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019
  • European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021
  • European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) (Amendment) Regulations 2025
  • Directive (EU) 2015/849 of the European Parliament and of the council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC
  • Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU
  • Directive (EU) 2018/1673 of the European Parliament and of the Council of 23 October 2018 on combating money laundering by criminal law
  • Directive (EU) 2024/1640 of the European Parliament and of the Council of 31 May 2024 on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Directive (EU) 2019/1937, and amending and repealing Directive (EU) 2015/849
  • Regulation (EU) 2024/1624 (Anti-Money Laundering Regulation)
  • Regulation (EU) 2024/1620 establishing the Authority for Anti-Money Laundering and Countering the Financing of Terrorism
  • Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849
  • Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937
  • FATF Recommendations
  • FATF Guidance on Proliferation Financing Risk Assessment and Mitigation
  • EBA Guidelines on ML/TF Risk Factors
  • Central Bank of Ireland AML/CFT Guidelines for the Financial Sector
  • Central Bank of Ireland Administrative Sanctions Procedure

Relevant regulators include:

  • Central Bank of Ireland
  • Financial Intelligence Unit Ireland
  • An Garda Siochana
  • Department of Justice
  • Department of Enterprise, Tourism and Employment
  • Department of Foreign Affairs
  • Revenue Commissioners and the Central Register of Beneficial Ownership of Trusts 
  • Companies Registration Office and the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies

Non-compliance with applicable AML/CFT and sanctions requirements can result in serious consequences, including supervisory intervention, directions, restrictions on business, administrative sanctions, public reprimands, monetary penalties, criminal liability, officer liability, asset-freezing consequences, remediation requirements, withdrawal or refusal of authorisation or registration, and other enforcement action by competent authorities.

The AML/CFT and Sanctions module maps regulatory consequences to each obligation, including offences under the Irish AML/CFT framework, Central Bank supervisory and administrative sanctions powers, sanctions-related penalties under applicable Irish statutory instruments, reporting failures, recordkeeping failures, tipping-off offences, governance failures and individual accountability consequences where relevant.

This module is designed for financial institutions, virtual asset service providers, payment and e-money institutions, funds and investment firms, credit and lending organisations, trust or company service providers, accountants, auditors, tax advisers, legal professionals, estate agents, high-value goods dealers, art-market participants and other designated persons or organisations responsible for AML/CFT and sanctions compliance in Ireland.

 

 

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