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AML/CTF Compliance in Ireland


Money laundering and terrorism financing laws in Ireland?


Key obligations that reporting entities have under Irish laws?

The key obligations under the AML/CTF laws in Ireland include:

  • Customer Due Diligence (CDD) - covered entities, including banks, financial institutions, money remitters, lawyers, accountants, auditors, estate agents, and other designated persons, are required to establish and implement risk-based CDD measures. This includes verifying the identity of customers, obtaining beneficial ownership information, and assessing the risk associated with each customer.
  • Enhanced Due Diligence (EDD) - in cases where there is a higher risk of money laundering or terrorism financing, such as when dealing with politically exposed persons (PEPs) or high-risk transactions, covered entities are required to apply enhanced due diligence measures. This may include obtaining additional information and conducting ongoing monitoring of the business relationship.
  • Reporting Suspicious Transactions - covered entities must report any knowledge, suspicion, or reasonable grounds for knowledge or suspicion of money laundering or terrorism financing to the Gardaí (Irish police) and the Revenue Commissioners. The reports should be made promptly when suspicion arises.
  • Record-Keeping - covered entities must maintain records of transactions, customer identification information, and supporting documentation for at least five years from the date of the last transaction. These records should be readily available for examination by regulatory authorities.
  • Compliance Programs - covered entities are expected to establish and maintain effective AML/CFT compliance programs. This includes implementing internal policies, procedures, and controls to detect, prevent, and report money laundering and terrorism financing activities. Staff training and regular independent audits are also important components of these programs.
  • Beneficial Ownership Reporting - companies and other legal entities incorporated in Ireland are required to maintain accurate and up-to-date beneficial ownership information and report it to the central register maintained by the Companies Registration Office (CRO)


ML/TF regulators in Ireland and what functions do they perform?

In Ireland, the regulators responsible for overseeing and enforcing anti-money laundering (AML) and counter-terrorism financing (CTF) measures are primarily:

  • Central Bank of Ireland - the Central Bank of Ireland is the main financial regulatory authority in Ireland. It plays a crucial role in supervising and regulating financial institutions, including banks, credit unions, insurance companies, and other entities operating in the financial sector.
  • Garda Síochána - Garda Síochána is the national police force of Ireland and works closely with other agencies to combat money laundering and terrorist financing activities. They are responsible for investigating and prosecuting money laundering offences.
  • Criminal Assets Bureau (CAB) - the CAB is a specialised law enforcement agency in Ireland tasked with tackling organised crime and confiscating assets derived from criminal activities. They play a role in combating money laundering through asset seizure and forfeiture.
  • Law Society of Ireland - the Law Society of Ireland  is the regulatory body for solicitors in Ireland. It sets and enforces professional standards, including AML regulations and guidelines for solicitors and law firms.
  • Institute of Chartered Accountants in Ireland (ICAI) - the ICAI is a professional accountancy body in Ireland. It provides guidance and regulations related to AML compliance for its members who are chartered accountants.
  • Property Services Regulatory Authority (PSRA) - the PSRA regulates and oversees the property services sector in Ireland, including estate agents, auctioneers, and property management companies. It ensures compliance with AML regulations within the industry.
  • Revenue Commissioners - the Revenue Commissioners in Ireland oversee tax administration and enforcement. They work closely with other agencies to combat financial crimes, including money laundering and tax evasion.

Ireland actively cooperates with international counterparts in combating money laundering and terrorism financing. This involves exchanging information, cooperating on investigations, and providing assistance to other jurisdictions when requested.


Industry sectors subject to ML/TF regulations?

In Ireland, the main industries that are regulated under the AML/CTF laws include:

Financial Institutions

Includes banks, credit unions, payment institutions, insurance companies, and other financial service providers.

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Legal Professionals

Includes solicitors, lawyers, barristers, and law firms.

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Includes chartered accountants and accounting firms.

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Real Estate Sector

Includes estate agents, auctioneers, property developers, and property management companies.

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High-Value Dealers

Includes businesses engaged in transactions involving high-value goods, such as art dealers, motor vehicle traders, and auction houses.

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Money Service Businesses (MSBs)

Includes currency exchange providers, money transfer services, and other money service businesses.

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Designated Non-Financial Businesses and Professions (DNFBPs)

Includes trust and company service providers, gambling operators, and other professionals such as auditors, tax advisors, and notaries

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Penalties for non-compliance with AML/CTF laws?

The Criminal Justice (Money Laundering and Terrorist Financing) Acts establish the regulatory framework for anti-money laundering (AML) and counter-terrorism financing (CTF) obligations in Ireland. Penalties for non-compliance with these obligations can include:

  • Administrative Penalties - the regulatory authorities, such as the Central Bank of Ireland, have the power to impose administrative fines for breaches of AML/CTF requirements. These fines can vary depending on the nature and severity of the violation. The maximum administrative fine that can be imposed is €5 million or 10% of annual turnover, whichever is greater
  • Criminal Offences - individuals or entities convicted of money laundering or terrorism financing offences can face fines imposed by the courts. The fines can vary based on the nature and severity of the offence. The court can impose unlimited fines
  • Imprisonment - convictions for money laundering or terrorism financing offences can result in imprisonment for individuals involved in such activities. The length of imprisonment can vary depending on the offence.
  • Disqualification - individuals convicted of money laundering or terrorism financing offences may face disqualification from serving as a director of a company or from carrying out certain regulated activities.
  • Regulatory Actions - regulatory authorities, such as the Central Bank of Ireland, have the power to take regulatory actions against individuals or entities, including revoking licences, imposing restrictions, or issuing public reprimands, for non-compliance with AML/CTF obligations.


Largest fines for non-compliance with AML/CTF laws?

Irish regulators have show they are willing to take action for non-compliance with AML/CTF laws and have used their powers extensively, below is an example of some of the largest fines for non-compliance with anti-money laundering laws:

  • Danske Bank - Danske Bank A/S fined €1,820,000 and reprimanded by the Central Bank of Ireland for transaction monitoring failures in respect of anti-money laundering and terrorist financing systems (12 September 2022).
  • Allied Irish Banks - Allied Irish Banks (AIB) was fined €2.3 million ($2.7 million) by the Central Bank of Ireland for breaches of AML/CTF regulations. The breaches included failures in customer due diligence and transaction monitoring (2019).
  • Permanent TSB - Permanent TSB was fined €4.5 million ($5.3 million) by the Central Bank of Ireland for AML/CTF failings. The bank was found to have inadequate systems and controls in place to prevent money laundering and terrorist financing (30 May 2019)
  • Ulster Bank - Ulster Bank, a subsidiary of Royal Bank of Scotland (RBS), was fined €3.5 million ($4.1 million) by the Central Bank of Ireland for AML/CTF failures. The bank had deficiencies in its control framework, which resulted in a failure to identify and report suspicious transactions (2013).