--- title: "Ireland (IE) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/ireland/ source_html: /jurisdictions/ireland/index.html description: "Financial integrity intelligence for Ireland (IE): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 8329fb00490c0892d865298e7a61ca47e5e32745f78a1c679c8ed077a56822dd generator: "fe-fleet/md-twin@1.0" --- # Ireland (IE) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Ireland IE Domains covered 8 of 8 Sources 166 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Clean Tier: A Risk direction: Increasing Enablement vs enforcement: Mixed Ireland's AML/CFT regime rests on the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010-2021 (5AMLD-transposing), with the Central Bank of Ireland as lead AML/CFT supervisor for financial institutions and VASPs, the FIU embedded in the Garda National Economic Crime Bureau, and the CRO/RBO handling corporate and beneficial-ownership registration. More As an EU member and international financial centre, Ireland will absorb the AMLR/AMLA package and MiCA in parallel. Key deficiencies - EU Commission-flagged inadequacy and inaccessibility of the beneficial ownership register of trusts under 4th/5th AMLD transposition - Persistently low money-laundering conviction rate after full trial despite a sound legislative framework, per FATF's 2017 MER, unresolved as of the 2022 follow-up - Structural exposure of Ireland's extractive/commodity export sector (Aughinish Alumina refinery) as an unintended conduit into Russian sanctioned arms supply chains - Complex, non-transparent fund and securitisation structures (QIAIFs, Section 110 SPVs) that increase third-party-reliance CDD vulnerabilities in the funds sector Recent developments (18m) - OCCRP investigation (published ~March 2026) revealing Aughinish Alumina (Rusal-owned, Co. Limerick) alumina exports reaching Russian smelters supplying EU-sanctioned arms manufacturers, triggering an Irish government probe and Oireachtas debate - President Zelenskyy's Dublin visit at the start of Ireland's EU Council presidency calling for closure of the Aughinish supply chain and EU sanctions loopholes - FATF confirmed Ireland absent from both the February 2026 and June 2026 Jurisdictions Under Increased Monitoring lists - Continued EU Commission pressure via infringement procedure over Ireland's trust beneficial-ownership register adequacy, opened April 2024 and unresolved - Ireland positioned among early-mover EU states (with France, Luxembourg, Lithuania) already implementing MiCA CASP requirements ahead of the July 2026 mandatory transition deadline Law made at European Economic Area level that applies in Ireland is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Ireland’s own layer: implementation, national authorities, national options and local enforcement. Brief ## Lead signal #### Lead Signal Ireland's financial-integrity posture this cycle is defined by a widening of administrative enforcement reach rather than by any single headline case. The European Union (Money Laundering and Terrorist Financing) (Administrative Sanctions) Regulations 2026 (S.I. No. 307/2026) entered into force on 30 June 2026, giving the Anti-Money Laundering Compliance Unit of the Department of Justice the power to impose administrative financial penalties on the Trust or Company Service Providers it supervises, in addition to the criminal offences that already existed under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. This closes a structural gap for a segment of enablers that sits outside Central Bank of Ireland supervision, and it is the kind of architecture-level change that matters more over time than any single prosecution: a supervisor that previously had only the criminal law as a lever now has a proportionate administrative tool it can use far more often. Read full brief #### Lead Signal Ireland's financial-integrity posture this cycle is defined by a widening of administrative enforcement reach rather than by any single headline case. The European Union (Money Laundering and Terrorist Financing) (Administrative Sanctions) Regulations 2026 (S.I. No. 307/2026) entered into force on 30 June 2026, giving the Anti-Money Laundering Compliance Unit of the Department of Justice the power to impose administrative financial penalties on the Trust or Company Service Providers it supervises, in addition to the criminal offences that already existed under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. This closes a structural gap for a segment of enablers that sits outside Central Bank of Ireland supervision, and it is the kind of architecture-level change that matters more over time than any single prosecution: a supervisor that previously had only the criminal law as a lever now has a proportionate administrative tool it can use far more often. Alongside this, Ireland's beneficial-ownership regime is moving toward defined statutory response timeframes for register-access requests, effective from 10 November 2026, under two implementing statutory instruments tied to the State's first National AML/CTF/PF Strategy. Together, the two developments point to the same direction of travel: tightening the administrative and procedural infrastructure around transparency and enabler oversight, ahead of the next FATF Mutual Evaluation of Ireland expected in 2028. #### Other Developments Crypto-asset market-abuse supervision reinforced. The Central Bank of Ireland confirmed on 12 October 2026 that it implements the European Securities and Markets Authority's guidelines specifying the supervisory practices national authorities must apply to prevent and detect insider dealing, unlawful disclosure and market manipulation involving crypto-assets under the Markets in Crypto-Assets Regulation. This is a direct publication by the national competent authority itself and signals continuing supervisory convergence across the EU around crypto-asset market integrity, layered on top of Ireland's already-concentrated population of authorised crypto-asset service providers. Cross-border intelligence-sharing architecture advances. The Anti-Money Laundering Authority's public consultation on draft Regulatory Technical Standards for cross-border information exchange between Financial Intelligence Units closed on 6 October 2026, with final text not yet published. Ireland, as an EU member state, is directly bound by the EU Anti-Money Laundering Regulation, and the sixth Anti-Money Laundering Directive transposition together with the Authority's supervisory build-out continue in parallel, with no sign this cycle of transposition lag specific to Ireland. Senior supervisory voice on fraud reporting and liability. A deputy governor of the Central Bank of Ireland was reported as saying that authorities should make it easier for scam victims to report offences and should clarify who must repay them, framing fraud as the leading financial-crime concern globally. No accompanying instrument or consultation was identified alongside these remarks this cycle, so this reads as a signal of direction rather than a completed structural step. #### Cross-Monitor Connections The administrative-sanctions expansion for Trust or Company Service Providers has a natural line of sight into enabler-jurisdiction oversight more broadly: a jurisdiction that adds a proportionate penalty tier for professional facilitators is narrowing one of the structural weaknesses that conflict-finance and sanctions-evasion networks have historically exploited through corporate-services intermediaries, even though no sanctions-specific Irish development was identified this cycle. The crypto-asset market-abuse guideline implementation also intersects with payments and digital-asset oversight conducted elsewhere in the fleet, since Ireland's concentrated population of authorised crypto-asset service providers sits at the intersection of market-conduct supervision and the broader digital-assets regulatory perimeter. The beneficial-ownership procedural tightening, meanwhile, is the kind of transparency-infrastructure change that corporate-structuring and enabler-jurisdiction analysis elsewhere in the fleet would want to track as it takes effect in November. #### Outlook Through the remainder of 2026, the clearest marker to watch is whether the Anti-Money Laundering Authority publishes final Regulatory Technical Standards on cross-border Financial Intelligence Unit information exchange following the October consultation closure, and whether the two statutory instruments underpinning the November beneficial-ownership access timeframes are identified with precision; their exact citations were not independently confirmed this cycle. The administrative-sanctions regime for Trust or Company Service Providers is now in force, but its practical bite will only become visible once the Anti-Money Laundering Compliance Unit is observed applying it. As scheduled, Ireland's FATF Mutual Evaluation review in 2028 remains a multi-year horizon rather than a near-term event, but the accumulation of these procedural and administrative changes positions Ireland to enter that evaluation with a materially tightened enabler-oversight and transparency architecture compared to the position at the start of 2026. Earlier periodic briefs (4) 20 Oct 2026 · fim-2026-10-20 #### Lead Signal Ireland's financial-integrity posture is defined by a widening of administrative enforcement reach rather than by any single headline case. The European Union (Money Laundering and Terrorist Financing) (Administrative Sanctions) Regulations 2026 (S.I. No. 307/2026) entered into force on 30 June 2026, giving the Anti-Money Laundering Compliance Unit of the Department of Justice the power to impose administrative financial penalties on the Trust or Company Service Providers it supervises, in addition to the criminal offences that already existed under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. This closes a structural gap for a segment of enablers that sits outside Central Bank of Ireland supervision, and it is the kind of architecture-level change that matters more over time than any single prosecution: a supervisor that previously had only the criminal law as a lever now has a proportionate administrative tool it can use far more often. Alongside this, Ireland's beneficial-ownership regime is moving toward defined statutory response timeframes for register-access requests, effective from 10 November 2026, under two implementing statutory instruments tied to the State's first National AML/CTF/PF Strategy. Together, the two developments point to the same direction of travel: tightening the administrative and procedural infrastructure around transparency and enabler oversight, ahead of the next FATF Mutual Evaluation of Ireland expected in 2028. #### Other Developments Crypto-asset market-abuse supervision reinforced. The Central Bank of Ireland confirmed on 12 October 2026 that it implements the European Securities and Markets Authority's guidelines specifying the supervisory practices national authorities must apply to prevent and detect insider dealing, unlawful disclosure and market manipulation involving crypto-assets under the Markets in Crypto-Assets Regulation. This is a direct publication by the national competent authority itself and signals continuing supervisory convergence across the EU around crypto-asset market integrity, layered on top of Ireland's already-concentrated population of authorised crypto-asset service providers. Cross-border intelligence-sharing architecture advances. The Anti-Money Laundering Authority's public consultation on draft Regulatory Technical Standards for cross-border information exchange between Financial Intelligence Units closed on 6 October 2026, with final text not yet published. Ireland, as an EU member state, is directly bound by the EU Anti-Money Laundering Regulation, and the sixth Anti-Money Laundering Directive transposition together with the Authority's supervisory build-out continue in parallel, with no sign of transposition lag specific to Ireland. Senior supervisory voice on fraud reporting and liability. A deputy governor of the Central Bank of Ireland was reported as saying that authorities should make it easier for scam victims to report offences and should clarify who must repay them, framing fraud as the leading financial-crime concern globally. No accompanying instrument or consultation was identified alongside these remarks, so this reads as a signal of direction rather than a completed structural step. #### Cross-Monitor Connections The administrative-sanctions expansion for Trust or Company Service Providers has a natural line of sight into enabler-jurisdiction oversight more broadly: a jurisdiction that adds a proportionate penalty tier for professional facilitators is narrowing one of the structural weaknesses that conflict-finance and sanctions-evasion networks have historically exploited through corporate-services intermediaries, even though no sanctions-specific Irish development was identified. The crypto-asset market-abuse guideline implementation also intersects with payments and digital-asset oversight conducted elsewhere in the fleet, since Ireland's concentrated population of authorised crypto-asset service providers sits at the intersection of market-conduct supervision and the broader digital-assets regulatory perimeter. The beneficial-ownership procedural tightening, meanwhile, is the kind of transparency-infrastructure change that corporate-structuring and enabler-jurisdiction analysis elsewhere in the fleet would want to track as it takes effect in November. #### Outlook Through the remainder of 2026, the clearest marker to watch is whether the Anti-Money Laundering Authority publishes final Regulatory Technical Standards on cross-border Financial Intelligence Unit information exchange following the October consultation closure, and whether the two statutory instruments underpinning the November beneficial-ownership access timeframes are identified with precision; their exact citations were not independently confirmed. The administrative-sanctions regime for Trust or Company Service Providers is now in force, but its practical bite will only become visible once the Anti-Money Laundering Compliance Unit is observed applying it. As scheduled, Ireland's FATF Mutual Evaluation review in 2028 remains a multi-year horizon rather than a near-term event, but the accumulation of these procedural and administrative changes positions Ireland to enter that evaluation with a materially tightened enabler-oversight and transparency architecture compared to the position at the start of 2026. 12 Oct 2026 · fim-2026-10-12 #### Lead Signal Ireland's beneficial-ownership access regime undergoes a structural tightening confirmed directly from primary statutory text: S.I. No. 335/2026, transposing the sixth Anti-Money Laundering Directive's harmonised access provisions, becomes operative on 10 November 2026 and replaces the restricted post-Sovim model with a legitimate-interest-category framework carrying a statutory 12-working-day Registrar response deadline. This is an architecture-over-incident development: it is not an enforcement action but a reordering of who may access the Register of Beneficial Ownership and on what terms, read against Ireland's broader AML regime posture. That posture was separately restated this cycle through Ireland's 2026 National Risk Assessment, its first since 2019, which rates money-laundering risk moderate, terrorist-financing and proliferation-financing risk low, and publishes Ireland's first standalone proliferation-financing threat assessment, accompanied by a 30-point Priority Actions Implementation Plan explicitly framed as preparation for the 2028 FATF Mutual Evaluation. Taken together, the two developments describe a jurisdiction consolidating its transparency and risk-assessment architecture ahead of a defined external accountability moment rather than reacting to a specific incident. The AMLD6 access reform is confirmed from the Irish Statute Book text itself and corroborated by independent law-firm commentary; the National Risk Assessment finding is confirmed directly from the Department of Finance publication. #### Other Developments EU sanctions designation cadence continues to accelerate. EU ambassadors are reported to have agreed, on 7 October 2026 and ahead of formal Council adoption, a package of roughly 1,650 new individual and entity listings concentrated on sectors supporting Russia's defence and missile-production base, building on the twenty-first package adopted 23 July 2026. This finding rests on press reporting rather than a published Council Regulation or Decision text, and is accordingly held at probable rather than confirmed pending formal adoption and Official Journal publication. As an EU and EEA member, Ireland would be bound once the package is formally adopted and published, extending the sanctions-architecture dimension of this cycle's signal beyond the beneficial-ownership reform. #### Cross-Monitor Connections The AMLD6 beneficial-ownership access reform sits at the architectural core of the EU AML Package and connects directly to the broader EU-level supervisory reorientation that the Package represents; firms relying on Irish Register of Beneficial Ownership access for customer due diligence should anticipate the formal legitimate-interest application and verification process replacing the pre-2026 approach from 10 November 2026. The sanctions-designation expansion connects to conflict-finance and extractive-industry-integrity analysis tracked elsewhere in the fleet, given the reported concentration on defence and missile-production-linked entities, though no Ireland-specific conflict-finance finding was identified this cycle to extend that linkage further. #### Outlook Ireland's National Risk Assessment and its accompanying 30-point Action Plan point toward a multi-year trajectory of increased supervisory attention across Central Bank of Ireland AML supervision, inter-agency information-sharing, and company-register verification, as the state positions itself ahead of the 2028 FATF Mutual Evaluation. The AMLD6 access reform taking effect 10 November 2026 is the nearer-term operational milestone: firms and researchers dependent on beneficial-ownership data should expect the new legitimate-interest-category application process and the 12-working-day statutory response window to become the operative reality from that date. Whether the reported EU sanctions expansion is formally adopted, and in what final scope, remains to be confirmed against the Official Journal; as scheduled, the broader divergence between the EU's sanctions cadence and recent UK and US listing activity bears watching across subsequent cycles. 6 Oct 2026 · fim-2026-10-06 #### Lead Signal Ireland's AML/CTF regime applies the European Commission high-risk third-country list directly through section 38A of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, and the mechanism is self-executing: when the Commission amends the list by delegated regulation, mandatory enhanced due diligence attaches domestically without need for a fresh Irish instrument. Delegated Regulations 2026/46 and 2026/83 added Russia, with effect from 29 January 2026, alongside Bolivia and the British Virgin Islands, so designated persons in Ireland are now required to apply the additional CJA 2010 s.38A measures to customers connected to those countries. This is Enhanced due diligence in FIM terms, distinct from the EU list of high-risk third countries used for other instruments and distinct from any FATF list; the EU list and the FATF lists diverge and are tracked on their own timelines. The structural point is that Ireland's exposure to EU list movement is immediate and automatic rather than mediated by domestic rulemaking, which concentrates attention on the EU delegated-act cycle itself as the operative event for Irish obliged entities rather than on any subsequent Irish transposition step. Around this confirmed addition sit several standing Irish AML provisions whose current text the research was able to read but whose most recent amendment history could not be fully verified this cycle. The electronic-money customer due diligence derogation in CJA 2010 s.33A, the trust beneficial-ownership register check in s.35(3A)-(3D), and the third-party reliance scope in s.40 are all still in force, but the consolidated text reviewed is dated no later than 1 August 2025, and later instruments referenced in secondary commentary have not yet been checked against the primary statute. #### Other Developments The electronic-money derogation remains narrow and conditional. Section 33A allows designated persons to skip the standard CDD measures for electronic money only where a cumulative set of conditions is met: the instrument is non-reloadable, or is usable only within the State with a maximum monthly load of one hundred fifty euro; stored value is capped at one hundred fifty euro; the instrument is restricted to goods or services; no anonymous funding is permitted; the instrument is subject to monitoring; and cash redemption and remote payment are each capped at fifty euro. The derogation does not apply where the customer is connected to a high-risk third country under s.38A or is a politically exposed person under s.37, meaning the two regimes interact rather than sit side by side. The consolidation underpinning this reading predates 1 August 2025, and S.I. 307/2026 and S.I. 335/2026 have not yet been checked against it, so the derogation's current boundaries should be treated as probable rather than confirmed pending a primary-source refresh. The beneficial-ownership register check remains a precondition to relationship, with an unresolved amendment question behind it. Under s.35(3A)-(3D), a designated person must confirm, before establishing a business relationship with a customer to which the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 apply, that the relevant trust's beneficial ownership is entered in the trust register or the Central Register of Beneficial Ownership. Secondary commentary points to amendments to the trust-register regime under S.I. 440/2025 and S.I. 335/2026, but the primary instruments themselves were not retrieved this cycle, so the current access route and verification mechanics remain an open finding. Third-party reliance under s.40 is bounded and does not transfer liability. Reliance is permitted only on a defined list of relevant third parties, meaning qualifying credit or financial institutions and listed professionals; it does not extend to undertakings that are financial institutions solely because they provide foreign-exchange or payment services. The reliance concept covers the s.33 and s.35(1) measures but not s.35(3) ongoing monitoring, and outsourcing providers or agents engaged under s.40(6)-(7) sit outside the reliance concept entirely, with the designated person, including an electronic-money institution, remaining liable for the outsourced function. No verbatim source text was admitted for this section this cycle, so this reading is recorded as pending confirmation rather than settled. Record-retention obligations continue unchanged. Section 55 requires a minimum five-year retention period for the records it covers, running from cessation of service or the last transaction with the customer, whichever is later, and that period can be extended by a further period on direction of the Garda Siochana. This is a standing obligation rather than a new development, and it bears on any cross-jurisdictional comparison of record-retention regimes. #### Cross-Monitor Connections The immediate, statute-driven uptake of EU high-risk third-country designations is the kind of enabler-and-exposure architecture that connects to conflict-finance and sanctions-evasion monitoring elsewhere in the fleet: a jurisdiction whose EDD trigger moves automatically with the EU list, rather than through domestic legislative lag, is structurally less permissive to abrupt changes in a counterparty's risk profile than one where transposition is discretionary or delayed. The open beneficial-ownership and third-party-reliance questions also bear on corporate-transparency and enabler-jurisdiction tracking: until the trust-register amendment chain and the outsourcing/reliance boundary are confirmed against primary text, Ireland's standing as a reliable node for verifying ultimate beneficial ownership in cross-border corporate structures carries a documented research-currency caveat rather than a settled finding. #### Outlook The near-term signal to watch is less about Ireland's own legislative calendar and more about the EU Commission's delegated-regulation cycle, since any future addition to or removal from the high-risk third-country list will have immediate domestic effect via s.38A without an intervening Irish instrument. Separately, closing the research-currency gaps on s.33A, s.35, and s.40 against the post-1 August 2025 instruments identified in the gaps register, namely S.I. 307/2026, S.I. 335/2026, and S.I. 440/2025, is likely to be the determining factor in whether this cycle's probable-confidence findings can be upgraded to confirmed in a subsequent cycle. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Ireland's 2026 National Risk Assessment has re-rated the crypto-asset sector's money-laundering and terrorist-financing risk from Medium-High in 2019 to Very Significant, a substantial escalation that the Department of Finance's own framing ties explicitly to preparation for Ireland's 2028 FATF Mutual Evaluation. The re-rating also flags crypto-asset misuse for sanctions evasion as a specific concern. This is architecture-level movement, not an incident report: it is a formal, government-published risk-rating change that will condition supervisory attention toward crypto-asset service providers over the medium term, with CASP authorisation under MiCA — the Central Bank of Ireland acting as sole National Competent Authority — as the operative supervisory perimeter through which that attention will be channelled. #### Other Developments AMLR/AMLA build-out framed explicitly around the 2028 evaluation. Ireland's 2026 NRA and its accompanying 30-point Priority Actions Implementation Plan are explicitly preparatory documents, positioning the state's supervisory capacity ahead of both the AMLR/AMLA supervisory build-out and the 2028 FATF Mutual Evaluation. As an EU-27 member, Ireland's application of the AML Regulation (Regulation (EU) 2024/1624) is direct rather than transposed, distinguishing this workstream from the sixth AML Directive's Member-State transposition track, whose Irish status was not established this cycle. Beneficial-ownership transparency remains structurally gated. Ireland's Registrar of Beneficial Ownership continues to restrict access to BO records to applicants who can demonstrate a legitimate interest in an ML/TF investigation, a standing condition dating to the 2022 CJEU ruling and a 2023 legislative restriction, and re-confirmed this cycle directly against the Registrar's own site rather than representing a fresh delta. This is a structural transparency limitation, not a new development, but it remains directly relevant to any enabler-jurisdiction assessment of Ireland's corporate-services sector: a gate that requires investigators to already have grounds for suspicion before they can access ownership records constrains the register's practical utility as a proactive detection tool. #### Cross-Monitor Connections The crypto-asset risk re-rating intersects directly with the crypto monitor's coverage of Ireland's MiCA CASP authorisation regime, where the Central Bank of Ireland's role as sole NCA and its active licensing of crypto-asset service providers is the supervisory perimeter through which the NRA's elevated risk rating will be operationalised; that licensing-architecture detail is that monitor's to carry. The beneficial-ownership access-restriction finding is relevant to any enabler-jurisdiction or corporate-transparency analysis conducted elsewhere in the fleet, given Ireland's corporate-services sector sits within the same CJEU-shaped access-restriction regime affecting other EU Member States' BO registers. #### Outlook The 2028 FATF Mutual Evaluation of Ireland is the anchoring horizon event for this cycle's developments: the crypto-asset risk re-rating and the AMLR/AMLA preparatory framing are both explicitly positioned by the Department of Finance as capacity-building ahead of that evaluation. Watch for further detail on the 30-point Priority Actions Implementation Plan as it is operationalised, and for whether increased supervisory attention to CASP-authorised entities materialises as concrete supervisory actions rather than remaining at the risk-rating level. Ireland's 6AMLD transposition status was not established this cycle and remains a gap worth resolving given its relevance to the same AMLR/AMLA build-out. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The EU's 20th and 21st Russia sanctions packages mark a material escalation in shadow-fleet and financial-institution designations this cycle, and the architecture matters more than any single listing. The 20th package, adopted 23 April 2026, added 34 individuals and 47 entities including Lukoil-Western Siberia and shadow-fleet-linked firms based in Russia, Liberia, Turkiye, the UAE, Azerbaijan, and Hong Kong, and added 46 vessels to bring the sanctioned shadow-fleet total to 632. The 21st package, adopted in July 2026, escalated further: 218 new listings, including 94 Russian financial institutions and the Moscow Exchange itself, the EU's first-ever bunkering-vessel sanctions targeting the logistics layer that keeps the shadow fleet operating, and, for the first time, transaction bans on 14 named third-country crypto-asset service providers and entities within the A7 payment network. This last element is the structurally significant one: it marks the EU's formal recognition of offshore crypto rails and adjacent payment networks as first-class sanctions-evasion infrastructure rather than a secondary concern layered onto banking-sector designations. The financial-institution designations within the 21st package, at 94 entities including the Moscow Exchange, extend the sanctions perimeter into core market infrastructure rather than only individual banks or shipping entities, which raises the correspondent-banking and clearing exposure of any institution still maintaining indirect channels into Russian financial markets. Both packages are corroborated by independent Tier 3 sources (gCaptain, Baltic Wind, and Hill Dickinson via gCaptain), though no Tier 1 primary EU Official Journal text was independently retrieved for either package this cycle, so the specific listing counts should be read as assessed to high-confidence rather than fully confirmed against primary text. Continue reading #### Outlook The trajectory across both packages points toward continued escalation rather than stabilisation: each successive package has extended further into financial-market infrastructure and, now, into crypto-asset and payment-network territory. Watch for whether subsequent EU packages name additional third-country crypto-asset service providers, which would confirm rather than merely suggest a durable policy shift toward treating crypto rails as first-order sanctions-evasion infrastructure, and for the practical enforcement follow-through on the new bunkering-vessel sanctions, which target logistics capacity rather than the vessels themselves. Judgment: No sanctions-architecture development identified for Ireland this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Ireland's beneficial-ownership transparency architecture sits within a standing EU structure that is itself reshaping how supervision of corporate transparency is organised across the bloc. That structure comprises three distinct instruments: the directly applicable Anti-Money Laundering Regulation, which applies uniformly across EU member states without domestic transposition; the sixth Anti-Money Laundering Directive, which each member state transposes into national law on its own timetable; and the Anti-Money Laundering Authority Regulation, which establishes the Anti-Money Laundering Authority itself and sets out a hybrid supervisory perimeter under which the Authority takes direct supervisory responsibility for a defined population of higher-risk cross-border obliged entities while national authorities retain responsibility for the remainder. This shift, from a purely national model of beneficial-ownership and transparency supervision toward one with an EU-level supervisory layer sitting above it, is the durable backdrop against which any Irish beneficial-ownership development should be read; it is not itself a development of this cycle, but it frames why procedural changes at the national level increasingly need to be understood in the context of an emerging EU-level oversight function. Continue reading Against that backdrop, the concrete development this cycle is procedural rather than architectural: new statutory response-timeframe obligations for beneficial-ownership register access requests are set to take effect from 10 November 2026, introduced through two implementing statutory instruments tied to Ireland's first National AML/CTF/PF Strategy. Previously, no defined statutory deadline governed how quickly access requests to the beneficial-ownership register had to be answered; the new timeframes close that gap. This is a meaningful procedural tightening because defined response deadlines change the practical experience of using the register, for obliged entities carrying out customer due diligence and for public or civil-society users seeking to verify corporate ownership, and they create an enforceable standard against which delay can be measured for the first time. At the same time, the precise statutory instrument numbers underpinning this change were not independently confirmed this cycle, which means the precise legal citation remains to be verified before the obligation can be fully pinned down in compliance terms. Read together, the EU-level architectural shift and the Irish procedural tightening point in the same direction: beneficial-ownership transparency is becoming more operationally rigorous, with defined service standards layered onto registers that, in many member states including Ireland, have existed for some years without such standards. For firms relying on the Irish register for customer due diligence, the practical significance is that register-access timelines should become more predictable and verifiable, once the implementing instruments are identified with certainty and their operation observed in practice from November. #### Outlook The period immediately following 10 November 2026 will be the first real test of whether the new statutory response timeframes function as intended in practice, and identifying the precise citations of the two implementing statutory instruments remains an open item. Separately, the Anti-Money Laundering Authority's continuing supervisory build-out, and the eventual finalisation of the draft Regulatory Technical Standards on cross-border Financial Intelligence Unit information exchange that closed for consultation on 6 October 2026, will continue to shape how beneficial-ownership and wider transparency data move between national authorities. Ireland's next FATF Mutual Evaluation, expected in 2028, gives these procedural developments a clear horizon against which their cumulative effect will eventually be tested. Judgment: No beneficial-ownership development identified for Ireland this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators The most structurally significant Irish development this cycle concerns the oversight of professional corporate-services facilitators rather than any single enforcement case. The European Union (Money Laundering and Terrorist Financing) (Administrative Sanctions) Regulations 2026, known by their statutory instrument number S.I. No. 307/2026, entered into force on 30 June 2026. The Regulations give the Anti-Money Laundering Compliance Unit within the Department of Justice the power to impose administrative financial penalties on the Trust or Company Service Providers that it supervises, for breaches of anti-money-laundering and counter-terrorist-financing obligations, operating alongside the criminal offences that already existed under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Continue reading This matters architecturally because Trust or Company Service Providers supervised by the Anti-Money Laundering Compliance Unit sit in a different supervisory category from those supervised by the Central Bank of Ireland, and historically that segment's primary deterrent was the criminal law alone, a blunt and comparatively rarely-used tool. The addition of an administrative-penalty regime gives the supervisor a tool it can deploy with greater frequency and proportionality, closing a gap that enabler-jurisdiction analysis has long flagged as a weakness: criminal-only regimes for corporate-services providers tend to produce under-enforcement, because prosecutors and courts set a high evidentiary bar relative to the administrative alternative. Ireland's own 2026 National Risk Assessment and Action Plan reaffirms existing sectoral risk ratings, rating Central-Bank-supervised Trust or Company Service Providers as low risk and Anti-Money-Laundering-Compliance-Unit-supervised providers as moderate risk, rather than signalling any shift in those ratings; the new administrative-sanctions power should be read as addressing that moderate-risk segment specifically, rather than as evidence of a reassessed risk picture. It is also notable, in the spirit of correcting for the usual under-weighting of absence of enforcement as a finding, that no Irish enforcement action under the new administrative-sanctions power has yet been identified; the power is newly in force, and its practical significance will only be demonstrated once the Anti-Money Laundering Compliance Unit is observed to use it against a supervised Trust or Company Service Provider. A power that exists on paper but has not yet been exercised is still a meaningful structural change, but it is one stage removed from a demonstrated deterrent effect. #### Outlook The Anti-Money Laundering Compliance Unit's actual use of its new administrative-sanctions power over the coming cycles will be the clearest signal of whether Ireland's enabler-jurisdiction oversight of Trust or Company Service Providers has moved from a paper gap-closure to a demonstrated one. Ireland's broader AML/CTF regime, including the ongoing Anti-Money Laundering Authority supervisory build-out and the sixth Anti-Money Laundering Directive transposition, continues in parallel and will shape how this administrative-sanctions power interacts with the EU-level supervisory architecture as it matures. Ireland's next FATF Mutual Evaluation, expected in 2028, will likely give particular scrutiny to whether this administrative tool has, by then, produced a visible enforcement record for the enabler segment it targets. Judgment: No enabler-jurisdiction development identified for Ireland this cycle. Uncertain Judgment: No conflict-finance development identified for Ireland this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation The Central Bank of Ireland confirmed on 12 October 2026 that it implements the European Securities and Markets Authority's guidelines specifying the supervisory practices that national competent authorities must apply to prevent and detect insider dealing, unlawful disclosure and market manipulation involving crypto-assets, under the Markets in Crypto-Assets Regulation. This is a direct, primary publication by Ireland's own national competent authority, rather than secondary commentary, and it carries the highest degree of confidence in this cycle's crypto-related findings. Continue reading The significance of this development lies less in any single enforcement action and more in what it signals about the maturity of Ireland's crypto-asset supervisory apparatus. Ireland has built up a concentrated population of authorised crypto-asset service providers under the Markets in Crypto-Assets Regulation, and confirming implementation of market-abuse-specific supervisory guidelines indicates that the Central Bank is extending its conduct-of-business oversight beyond the baseline authorisation and prudential requirements and into the market-integrity dimension of crypto-asset activity. This is a textbook example of the kind of structural, architecture-level signal that matters more than any individual incident: a national competent authority formally adopting supervisory guidance on market abuse in crypto-assets indicates its internal supervisory capability for this sector is deepening, ahead of any specific case that might test it. From a financial-integrity perspective, this development sits at the intersection of market-conduct supervision and the broader anti-money-laundering and countering-the-financing-of-terrorism architecture that governs crypto-asset service providers in Ireland. Market-abuse supervision and anti-money-laundering supervision are, in principle, distinct regulatory objectives, but in practice the same concentrated population of authorised firms is subject to both, and a supervisor that strengthens its market-abuse detection capability is also, functionally, improving its overall visibility into the trading and transactional behaviour of the sector it supervises. No specific enforcement action or named crypto-asset service provider was identified in connection with market abuse this cycle; the finding is that the supervisory guideline-implementation step itself has been confirmed. #### Outlook The practical test of this guideline implementation will come whenever the Central Bank of Ireland is next observed applying its market-abuse supervisory framework to a specific crypto-asset case, whether through an investigation, an enforcement action or a public statement. In the interim, the confirmed implementation reinforces the broader EU-wide pattern of supervisory convergence around crypto-asset market integrity under the Markets in Crypto-Assets Regulation, a pattern against which Ireland's concentrated authorised-firm population makes it a jurisdiction worth continued attention within the financial-integrity dimension of crypto-asset oversight. Judgment: No crypto/digital-asset development identified for Ireland this cycle under D5. Uncertain Judgment: No RegTech / active-defence development identified for Ireland this cycle. Uncertain #### AML/CTF Regime Ireland's AML/CTF regulatory posture this cycle is defined by explicit preparatory alignment ahead of two converging events: the EU's AMLR/AMLA supervisory build-out and Ireland's own 2028 FATF Mutual Evaluation. Ireland's 2026 National Risk Assessment and its accompanying 30-point Priority Actions Implementation Plan are framed by the Department of Finance as preparatory documents for both. As an EU-27 member, Ireland's application of the AML Regulation (Regulation (EU) 2024/1624) is direct — it does not require domestic transposition in the way the sixth AML Directive does — while the AMLA Regulation (Regulation (EU) 2024/1620) establishes the Anti-Money Laundering Authority that will progressively take on direct and indirect supervisory responsibility for higher-risk obliged entities across the EU, including in Ireland. Ireland's specific 6AMLD transposition status was not established this cycle and remains an open gap. Continue reading Separately and as a standing structural condition rather than a fresh development, Ireland's Registrar of Beneficial Ownership continues to restrict BO-record access to applicants demonstrating a legitimate interest in an ML/TF investigation. This restriction dates to a 2022 CJEU ruling and a 2023 legislative response, and was re-confirmed this cycle by direct reference to the Registrar's own published position rather than through any new legal development. The persistence of this legitimate-interest gate is directly relevant to the AML/CFT regime's transparency dimension: a beneficial-ownership register that requires pre-existing investigative grounds before access is granted functions differently, as a due-diligence and detection tool, than one open to broader access, and this distinction is a standing feature of Ireland's regime that any AML/CFT assessment should account for. Taken together, these two threads — direct AMLR application ahead of the 2028 evaluation, and a structurally gated beneficial-ownership register — describe a regime that is actively preparing its supervisory architecture for external assessment while carrying a known, longstanding transparency limitation into that assessment window. #### Outlook Ireland's 2028 FATF Mutual Evaluation is the fixed point against which the AMLR/AMLA build-out and the NRA's 30-point plan should both be read. Resolving Ireland's 6AMLD transposition status, and clarifying whether the AMLA's direct-supervision perimeter will extend to any Ireland-based obliged entities in the near term, are the two clearest gaps that subsequent cycles should aim to close. Judgment: AMLA held a public hearing on its draft RTS establishing a centralised AML/CFT database; this EU-level rulebook item will feed into supervisory information-sharing arrangements applicable to Irish AML/CTF supervised entities once adopted, but has not yet changed the standing regime. Probable Judgment: No commercial transaction identified in the financial-integrity market for Ireland this cycle. Uncertain Regulatory horizon In Force Pending 10 Nov 2026 · ±quarter ### Ireland's AMLD6 beneficial-ownership access regime becomes operative Access to Irish BO registers for trusts and corporate entities moves to a harmonised AMLD6 legitimate-interest-category model with a statutory 12-working-day Registrar response time. [Source](https://www.irishstatutebook.ie/eli/2026/si/335/made/en/print) In Force Pending 2027-Q2 · ±quarter ### Gambling Regulation Act 2024 s.230 AML-supervisor handover to GRAI AML/CFT supervisory responsibility for gambling service providers moves to GRAI, which already holds administrative fining power up to EUR 20m or 10% of turnover for licensing breaches. [Department of Justice / GRAI Source](https://europeangaming.eu/portal/latest-news/2026/08/18/212836/ireland-national-aml-strategy-gambling/) Consultation 2028 · ±multi_year ### 2028 FATF Mutual Evaluation of Ireland Increased supervisory attention to crypto-asset risk, beneficial-ownership transparency and capacity-building in the run-up to 2028. [FATF Source](https://www.williamfry.com/knowledge/irelands-2026-national-risk-assessment/) 3 dated · 3 pending date · baseline fim-2026-07-10 Role action cards MLRO ### A new administrative-penalty power for Trust or Company Service Provider supervision took effect, alongside tightened beneficial-ownership access timeframes. The entry into force of administrative sanctions for Anti-Money-Laundering-Compliance-Unit-supervised Trust or Company Service Providers gives the Irish supervisor a lower-threshold enforcement tool than the existing criminal offences, which may change the practical risk calculus for firms with exposure to that enabler segment. The new beneficial-ownership access response timeframes, effective from 10 November 2026, are also relevant to due-diligence workflows that rely on timely register access. 2 evidence refs Compliance ### Administrative sanctions for Trust or Company Service Providers are now in force under S.I. No. 307/2026. Firms with Trust or Company Service Provider exposure supervised by the Anti-Money Laundering Compliance Unit should be aware that administrative financial penalties, not only criminal offences, are now available to the supervisor as of 30 June 2026. 1 evidence refs Board ### Ireland's enabler-oversight and beneficial-ownership transparency architecture tightened procedurally this cycle. Two structural developments, the administrative-sanctions regime for Trust or Company Service Providers and the new beneficial-ownership access timeframes, together with confirmed implementation of EU crypto-asset market-abuse supervisory guidelines, indicate continued strengthening of Ireland's financial-integrity supervisory architecture ahead of its 2028 FATF Mutual Evaluation. 3 evidence refs CTO ### The Central Bank of Ireland confirmed implementation of EU crypto-asset market-abuse supervisory guidelines. Technology and platform teams supporting Irish-authorised crypto-asset service providers should note that market-abuse detection and supervisory engagement around crypto-asset trading infrastructure is an area of active regulatory convergence at the EU level. 1 evidence refs Risk ### A structural enforcement gap for Trust or Company Service Provider oversight has been closed with a new administrative-sanctions power. The move from a criminal-only to a criminal-plus-administrative sanctions regime for a defined enabler segment reduces the enforcement-threshold risk that previously characterised that segment's oversight, though no enforcement action under the new power has yet been observed. 1 evidence refs Audit ### New statutory response timeframes for beneficial-ownership register access take effect from 10 November 2026. Audit and control-testing scope relying on beneficial-ownership register access timeliness should account for the new statutory deadlines once the underlying implementing instruments are identified with certainty. 1 evidence refs Scenario sketches ### Illustrative AMLA supervisory transition and cross-border enabler evasion pathways As the Anti-Money Laundering Authority's direct and indirect supervisory perimeter matures alongside the directly applicable Anti-Money Laundering Regulation and ongoing sixth Anti-Money Laundering Directive transposition across member states, one illustrative structural possibility is that obliged entities operating across several member states could, in principle, face a more harmonised supervisory experience for cross-border activity, while entities and facilitators operating just outside that harmonised perimeter, such as smaller domestically-supervised corporate-services providers, could see relatively less attention in the near term simply because EU-level supervisory resources are concentrated on the higher-risk cross-border population the Authority is designed to oversee directly. This is an illustrative structural possibility only, not an observed shift in Irish supervisory practice. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Sanctions Architecture and Evasion no_change T2 · EU AML Package Implementation (AMLR / 6AMLD / AMLA) watch AMLA public hearing on draft RTS for a centralised AML/CFT database (consultation stage). T3 · Enabler Jurisdiction Dynamics no_change T4 · Crypto / Digital Asset Illicit Finance no_change T5 · Compliance Technology and RegTech Adoption no_change T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 6 Nov 2025 - 30 Jun 2026 - 21 Jul 2025 - 30 Jun 2026 - Coordinated arrests and cash seizures spanning Newry (Northern Ireland) and the Republic of Ireland; two men arrested by An Garda Síochána with a further search seizing £176,000, connected to an earlier Newry seizure of approximately €450,000 and £258,000. 28 May 2026 - Following the OCCRP investigation, the Irish government confirmed it was examining reports that alumina from the Aughinish refinery was reaching Russian smelters supplying EU-sanctioned arms manufacturers; the issue was raised in the Oireachtas and by the Taoiseach. 24 Mar 2026 - The European Commission opened an infringement procedure against Ireland (alongside France and Latvia) for incorrect transposition of the 4th and 5th Anti-Money Laundering Directives, specifically citing inadequacy and inaccessibility of Ireland's beneficial ownership register of trusts. 24 Apr 2024 ### Sanctions changes - 26 May 2026 - 30 Jun 2026 - 18 Jul 2026 - 23 Apr 2026 - 16 Jan 2026 - 7 Oct 2026 - The EU's 19th sanctions package against Russia targeted Russian energy revenues, third-country banks facilitating evasion, and crypto asset service providers, alongside export restrictions on 45 new entities including some in third countries supplying dual-use goods. As an EU member, Ireland implements these measures directly. 23 Oct 2025 - The EU Council sanctioned 41 additional vessels of Russia's shadow fleet (18 December 2025) and 9 shadow-fleet enablers (15 December 2025), imposing port-access bans and maritime-service restrictions, directly applicable in Ireland as an EU coastal member state with significant port infrastructure. 18 Dec 2025 - Despite the Aughinish Alumina revelations, no EU sanctions listing has yet been added specifically closing the alumina/aluminium re-export channel; Belgium and several MEPs are lobbying the Commission to expand the sanctions regime, while the Irish government's own review remains open, illustrating a live gap between the sanctions regime's letter and its intended strategic effect. 24 Mar 2026 ### Regulatory horizon (register) - UK ECCTA 2023 failure-to-prevent-fraud offence — first full year of enforceability - 2028 FATF Mutual Evaluation of Ireland - FATF Fifth-Round Mutual Evaluation of Ireland - Gambling Regulation Act 2024 s.230 AML-supervisor handover to GRAI - Ireland's AMLD6 beneficial-ownership access regime becomes operative - Ireland's 2028 FATF Mutual Evaluation preparation - AMLA draft RTS for central AML/CFT database - MiCA transitional period closes for crypto asset service providers - AML Regulation (AMLR) direct-applicability start for Ireland - AMLA direct/indirect supervisory perimeter build-out affecting Irish entities - Ireland's next FATF mutual evaluation (5th round) scheduling ### Active schemes - [CRITICAL] Irish alumina refinery feeding sanctioned Russian arms chain - [HIGH] Trust and fund-vehicle beneficial ownership opacity - VASP-to-CASP transitional crypto compliance gap - Cross-border cash recycling by island-of-Ireland organised crime Sources - [FATF](https://www.fatf-gafi.org/en/the-fatf/news.html) - [AGB (Asia Gaming Brief)](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [U.S. Department of Commerce (trade.gov)](https://www.trade.gov/country-commercial-guides/laos-trade-financing) - [FinCEN](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0545) - [Central Bank of Ireland](https://www.centralbank.ie/news/article/press-release-enforcement-action-against-coinbase-europe-limited-6-November-2025) - [Arthur Cox LLP](https://www.arthurcox.com/insights/irelands-aml-cft-action-plan-2026-2027/) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Colombia-2023.html) - [Licentium](https://www.licentium.io/post/ireland-grai-remote-betting-licences-1-july-2026) - [Narvi](https://narvi.com/blog/mica-eu-regulation) - [ESMA](https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica) - [https://news.bitcoin.com/ireland-targets-crypto-assets-in-new-strategy-to-disrupt-illicit-cash-flows/](https://news.bitcoin.com/ireland-targets-crypto-assets-in-new-strategy-to-disrupt-illicit-cash-flows/) - [https://www.arthurcox.com/insights/irelands-aml-cft-action-plan-2026-2027/](https://www.arthurcox.com/insights/irelands-aml-cft-action-plan-2026-2027/) - [https://eucrim.eu/news/new-anti-money-laundering-directive-amld-6/](https://eucrim.eu/news/new-anti-money-laundering-directive-amld-6/) - [https://gcaptain.com/eu-targets-russian-shadow-fleet-banks-and-crypto-in-sweeping-21st-sanctions-package/](https://gcaptain.com/eu-targets-russian-shadow-fleet-banks-and-crypto-in-sweeping-21st-sanctions-package/) - [https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/](https://agbrief.com/news/cambodia/26/01/2026/cambodia-battles-to-avoid-third-fatf-grey-list-placement-amid-scam-crackdown/) - [https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern](https://www.fincen.gov/news/news-releases/fincen-issues-supplemental-alert-fuel-smuggling-and-tax-evasion-schemes-southern) - [https://hacken.io/discover/mica-regulation/](https://hacken.io/discover/mica-regulation/) - [https://www.trowers.com/insights/2026/march/fraud-what-lies-ahead-for-2026](https://www.trowers.com/insights/2026/march/fraud-what-lies-ahead-for-2026) - [https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [https://balticwind.eu/eu-sanctions-target-russias-shadow-fleet-and-energy-revenues/](https://balticwind.eu/eu-sanctions-target-russias-shadow-fleet-and-energy-revenues/) - [https://www.williamfry.com/knowledge/irelands-2026-national-risk-assessment/](https://www.williamfry.com/knowledge/irelands-2026-national-risk-assessment/) - [https://cro.ie/registration/beneficial-ownership/](https://cro.ie/registration/beneficial-ownership/) - [https://enterprise.gov.ie/en/who-we-are/offices-agencies/registrar-of-beneficial-ownership-rbo-.html](https://enterprise.gov.ie/en/who-we-are/offices-agencies/registrar-of-beneficial-ownership-rbo-.html) - [https://www.fatf-gafi.org/en/countries/detail/Ireland.html](https://www.fatf-gafi.org/en/countries/detail/Ireland.html) - [https://www.lexology.com/library/detail.aspx?g=0250361c-58e0-4aa8-9840-2055918dc5ce](https://www.lexology.com/library/detail.aspx?g=0250361c-58e0-4aa8-9840-2055918dc5ce) - [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html) - [https://www.centralbank.ie/regulation/anti-money-laundering-and-countering-the-financing-of-terrorism/eu-international](https://www.centralbank.ie/regulation/anti-money-laundering-and-countering-the-financing-of-terrorism/eu-international) - [https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [https://eur-lex.europa.eu/eli/reg_del/2025/1184/oj/eng](https://eur-lex.europa.eu/eli/reg_del/2025/1184/oj/eng) - [https://revisedacts.lawreform.ie/eli/2010/act/6/revised/en/html](https://revisedacts.lawreform.ie/eli/2010/act/6/revised/en/html) - [https://revisedacts.lawreform.ie/eli/2010/act/6/section/40/revised/en/html](https://revisedacts.lawreform.ie/eli/2010/act/6/section/40/revised/en/html) - [https://www.centralbank.ie/docs/default-source/regulation/amld-/guidance/anti-money-laundering-and-countering-the-financing-of-terrorism-guidelines-for-the-financial-sector.pdf](https://www.centralbank.ie/docs/default-source/regulation/amld-/guidance/anti-money-laundering-and-countering-the-financing-of-terrorism-guidelines-for-the-financial-sector.pdf) - [https://revisedacts.lawreform.ie/eli/2010/act/6/section/55/revised/en/html](https://revisedacts.lawreform.ie/eli/2010/act/6/section/55/revised/en/html) - [https://assets.gov.ie/static/documents/07bf6929/National_Risk_Assessment_Ireland_2026.pdf](https://assets.gov.ie/static/documents/07bf6929/National_Risk_Assessment_Ireland_2026.pdf) - [https://www.irishstatutebook.ie/eli/2026/si/335/made/en/print](https://www.irishstatutebook.ie/eli/2026/si/335/made/en/print) - [https://www.themoscowtimes.com/2026/10/07/eu-approves-record-sanctions-expansion-targeting-16k-russian-citizens-and-entities-a93913](https://www.themoscowtimes.com/2026/10/07/eu-approves-record-sanctions-expansion-targeting-16k-russian-citizens-and-entities-a93913) - [https://vendors.ie/fintech/register](https://vendors.ie/fintech/register) - [https://www.amlintelligence.com/2026/10/news-irish-central-bank-official-urges-clearer-scam-reporting-and-liability-rules/](https://www.amlintelligence.com/2026/10/news-irish-central-bank-official-urges-clearer-scam-reporting-and-liability-rules/) - [https://www.amlcompliance.ie/notifications/](https://www.amlcompliance.ie/notifications/) - [https://www.centralbank.ie/regulation/markets-update/esma-guidelines-and-recommendations/issue-16-2026/central-bank-of-ireland/crypto-assets--the-central-bank-of-ireland-implements-esma-guidelines-on-market-abuse-in-the-context-of-the-markets-in-crypto--assets-(mica)-regulation](https://www.centralbank.ie/regulation/markets-update/esma-guidelines-and-recommendations/issue-16-2026/central-bank-of-ireland/crypto-assets--the-central-bank-of-ireland-implements-esma-guidelines-on-market-abuse-in-the-context-of-the-markets-in-crypto--assets-(mica)-regulation) - [https://www.mccannfitzgerald.com/knowledge/financial-services-regulation/know-your-risk-what-irelands-2026-aml-cft-pf-national-risk-assessment-and-action-plan-mean-for-firms](https://www.mccannfitzgerald.com/knowledge/financial-services-regulation/know-your-risk-what-irelands-2026-aml-cft-pf-national-risk-assessment-and-action-plan-mean-for-firms) - [Law Society of Ireland](https://www.lawsociety.ie/Solicitors/regulation/anti-money-laundering-aml/) - [Mutual Evaluation of Ireland](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofireland.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Ireland](https://www.fatf-gafi.org/en/countries/detail/Ireland.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Ireland's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-ireland-2022.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Ireland's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-ireland-2017.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Money laundering and terrorist financing risks](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Ml-tf-risks.html) - [Bank of Ireland Fined $3.52 Million For Breaching Money Laundering Rules | OCCRP](https://www.occrp.org/en/news/bank-of-ireland-fined-352-million-for-breaching-money-laundering-rules) - [Irish Bank Fined for not Preventing Money Laundering | OCCRP](https://www.occrp.org/en/news/irish-bank-fined-for-not-preventing-money-laundering) - [Ireland's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-ireland-2017.html) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov](https://www.fincen.gov/) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer4/mer-ireland-2017.pdf) - [Ireland Central Bank Warns Lenders on Transparency in Tough Times - Bloomberg](https://www.bloomberg.com/news/articles/2022-09-30/irish-central-bank-warns-lenders-on-transparency-in-tough-times) - [Mortgage Scandal: AIB Hit With Ireland Central Bank Record Fine for Overcharging - Bloomberg](https://www.bloomberg.com/news/articles/2022-06-23/aib-to-face-possible-record-irish-fine-over-mortgages-scandal) - [Bank of Ireland Hit With Record Fine in Tracker Mortgage Scandal - Bloomberg](https://www.bloomberg.com/news/articles/2022-09-29/bank-of-ireland-hit-with-record-fine-in-tracker-mortgage-scandal) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [Information on Ireland national BOR - European Union](https://webgate.ec.europa.eu/e-justice/fileDownload.do?id=409babc2-fc9e-4ec5-98c1-98bf9bd23744) - [GOVERNMENT OF IRELAND persons with significant control - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE031961/persons-with-significant-control) - [Register an overseas entity and its beneficial owners - GOV.UK](https://www.gov.uk/guidance/register-an-overseas-entity) - [GOVERNMENT OF IRELAND overview - Companies House](https://find-and-update.company-information.service.gov.uk/company/OE031961) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [contact (northern ireland) - Companies House - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/NI030452) - [BOI E-FILING](https://boiefiling.fincen.gov/) - [Beneficial Ownership Registers Interconnection System](https://webgate.ec.europa.eu/e-justice/searchBoris.do) - [European e-Justice Portal - Business registers in EU countries](https://webgate.ec.europa.eu/e-justice/106/EN/business_registers_in_eu_countries?IRELAND=&init=true&member=1) - [government of ireland - Companies House - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE031961/more) - [Potential Money Laundering Risks Related to Shell Companies | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance/potential-money-laundering-risks-related-shell-companies) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer4/MER-Ireland-2017.pdf) - [The Role of Domestic Shell Companies in Financial Crime ...](https://www.fincen.gov/sites/default/files/shared/LLCAssessment_FINAL.pdf) - [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Ireland) - [Financial Crimes Enforcement Network The Role of Domestic Shell Companies in](https://www.fincen.gov/system/files/shared/LLCAssessment_FINAL.pdf) - [Inside scandal-rocked Danske Estonia and the shell-company 'factories' that served it - ICIJ](https://www.icij.org/investigations/fincen-files/inside-scandal-rocked-danske-estonia-and-the-shell-company-factories-that-served-it/) - [Securitisation companies and structured finance vehicles](https://www.legislation.gov.uk/uksi/2014/2080/article/3/data.html) - [Controversial shell-company ‘factories’ seek a role cleaning up UK's reputation - ICIJ](https://www.icij.org/investigations/fincen-files/controversial-shell-company-factories-seek-a-role-cleaning-up-uks-reputation/) - [EU economic policy and Ireland - European Commission](https://ireland.representation.ec.europa.eu/strategy-and-priorities/key-eu-policies-ireland/eu-economic-policy-and-ireland_en) - [EU Faces Pressure to Close Irish Alumina Loophole After Russian Arms Link | OCCRP](https://www.occrp.org/en/news/eu-faces-pressure-to-close-irish-alumina-loophole-after-russian-arms-link) - [Statement on the sixth Sanctions Coordinators Forum - Finance](https://finance.ec.europa.eu/news/statement-sixth-sanctions-coordinators-forum-2025-10-28_en) - [OFFICIAL OFFICIAL 1 Red ALERT Financial Sanctions Evasion](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/605-necc-financial-sanctions-evasion-russian-elites-and-enablers/file) - [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Russia sanctions: statutory guidance - GOV.UK](https://www.gov.uk/government/publications/russia-sanctions-guidance/russia-sanctions-guidance) - [Zelensky Demands Severing of Russian Supply Chains; Targets Irish Refinery | OCCRP](https://www.occrp.org/en/news/zelensky-demands-severing-of-russian-supply-chains-targets-irish-refinery) - [Overview of sanctions and related resources - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-resources_en) - [The UK Sanctions List - GOV.UK](https://www.gov.uk/government/publications/the-uk-sanctions-list) - [Ireland Country Guide | Elliptic](https://www.elliptic.co/country-guides/ireland) - [European Commission calls on Ireland to correctly transpose the 5th Anti-Money Laundering Directive](https://ireland.representation.ec.europa.eu/news-and-events/news/european-commission-calls-ireland-correctly-transpose-5th-anti-money-laundering-directive-2024-04-24_en) - [Lebanon’s Central Bank Chief Riad Salameh Charged With Money Laundering - Bloomberg](https://www.bloomberg.com/news/articles/2022-03-21/lebanon-judge-charges-central-bank-chief-with-money-laundering) - [September 2017 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER-Ireland-2017.pdf.coredownload.inline.pdf) - [Anti-money laundering and countering the financing of terrorism at EU level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) - [Anti-money laundering directive V (AMLD V) - transposition status | European Commission](https://ec.europa.eu/info/publications/anti-money-laundering-directive-5-transposition-status_en) - [Anti-money laundering and countering the financing of terrorism legislative package - Finance](https://finance.ec.europa.eu/publications/anti-money-laundering-and-countering-financing-terrorism-legislative-package_en) - [Homepage - Authority for Anti-Money Laundering and Countering the Financing of Terrorism](https://finance.ec.europa.eu/financial-crime/amla_en/) - [Timeline: EU action against money laundering and terrorist financing - Consilium](https://www.consilium.europa.eu/en/policies/fight-against-terrorist-financing/timeline/) - [Anti-money laundering: Council adopts package of rules - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/05/30/anti-money-laundering-council-adopts-package-of-rules/) - [Anti-money laundering: Council agrees its position on a strengthened rulebook - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2022/12/07/anti-money-laundering-council-agrees-its-position-on-a-strengthened-rulebook/) - [NIS2 Directive implementation in Ireland | Shaping Europe’s digital future](https://digital-strategy.ec.europa.eu/en/policies/nis2-directive-ireland) - [Money Laundering National Risk Assessment Guidance](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Guidance.html) - [FATF launches National Risk Assessment toolkit to help countries identify greatest money laundering risks](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-launches-National-Risk-Assessment-toolkit-to-help-countries-identify-greatest-money-laundering-risks.html) - [Public consultation on FATF Money Laundering National Risk Assessment Guidance Update](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/FATF-NRA-National-Risk-Assessments-Guidance-Public-Consultation-2024.html) - [FATF GUIDANCE Money Laundering National Risk Assessment Guidance November 2024](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money-Laundering-National-Risk-Assessment-Guidance-2024.pdf.coredownload.inline.pdf) - [MONEY LAUNDERING NATIONAL RISK ASSESSMENT TOOLKIT – ANNEXES A-C](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Money-Laundering-National-Risk-Assessment-Toolkit-Annexes.html) - [July 2025 National Risk Assessment of Money Laundering and](https://assets.publishing.service.gov.uk/media/6877be59760bf6cedaf5bd4f/National_Risk_Assessment_of_Money_Laundering_and_Terrorist_Financing_2025_FINAL.pdf) - [National risk assessment of money laundering and terrorist financing 2025 - GOV.UK](https://www.gov.uk/government/publications/national-risk-assessment-of-money-laundering-and-terrorist-financing-2025) - [HM Treasury national risk assessment 2025](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-national-risk-assessment-2025) - [NCA and FCA publish priorities to combat biggest economic crime threats - National Crime Agency](https://www.nationalcrimeagency.gov.uk/news/nca-and-fca-publish-priorities-to-combat-biggest-economic-crime-threats) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [IDG52700 - Information disclosure Gateways with other government departments: Irish Criminal Assets Bureau - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/information-disclosure-guide/idg52700) - [Cross border arrests in international money laundering investigation - National Crime Agency](https://www.nationalcrimeagency.gov.uk/news/cross-border-arrests-in-international-money-laundering-investigation) - [PCTF seize NI properties under Proceeds of Crime Act - National Crime Agency](https://www.nationalcrimeagency.gov.uk/news/pctf-seize-ni-properties-under-proceeds-of-crime-act) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [Long: Removing profits an important tool in fight against organised crime | Department of Justice](https://www.justice-ni.gov.uk/news/long-removing-profits-important-tool-fight-against-organised-crime) - [December 2025 Anti-Money Laundering and Counter-Terrorist Financing](https://assets.publishing.service.gov.uk/media/693308125b5198836f304150/24-25_Annual_Report_.pdf) - [BlueLeaks: FBI Aware Large Investment Funds Enable Money Laundering | OCCRP](https://www.occrp.org/en/news/blueleaks-fbi-aware-large-investment-funds-enable-money-laundering) - [FinCEN Alert Russian Elites High Value Assets](https://www.fincen.gov/system/files/2022-03/FinCEN%20Alert%20Russian%20Elites%20High%20Value%20Assets_508%20FINAL.pdf) - [Mysterious Group of Companies Tied to Bank Rossiya Unites Billions of Dollars in Assets Connected to Vladimir Putin | OCCRP](https://www.occrp.org/en/project/russian-asset-tracker/mysterious-group-of-companies-tied-to-bank-rossiya-unites-billions-of-dollars-in-assets-connected-to-vladimir-putin) - [Home](https://www.fatf-gafi.org/en/home.html) - [Ireland Strategic Investment Fund - Company Profile and News - Bloomberg Markets](https://www.bloomberg.com/profile/company/1305920D:ID) - [ICIJ's guide to Russian wealth hidden offshore - ICIJ](https://www.icij.org/investigations/russia-archive/icijs-guide-to-russian-wealth-hidden-offshore/) - [Press Releases | FinCEN.gov](https://www.fincen.gov/news/press-releases) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Guidance | FinCEN.gov](https://www.fincen.gov/resources/statutes-regulations/guidance) - [Alerts/Advisories/Notices/Bulletins/Fact Sheets | FinCEN.gov](https://www.fincen.gov/resources/advisoriesbulletinsfact-sheets) - [Important Information for MSBs | FinCEN.gov](https://www.fincen.gov/resources/financial-institutions/money-services-businesses?field_date_release_value=&field_date_release_value_1=&type=All&page=2) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [Enforcement Actions for Failure to Register as a Money Services Business | FinCEN.gov](https://www.fincen.gov/enforcement-actions-failure-register-money-services-business) - [News | FinCEN.gov](https://www.fincen.gov/news) - [What the end of MiCA's transitional period means for crypto businesses](https://www.elliptic.co/blog/the-end-of-micas-transitional-period) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [Quick guide on assessing the Money Laundering risks of virtual assets (VA) and virtual asset service providers (VASP)](https://www.fatf-gafi.org/en/publications/Methodsandtrends/quick-guide-on-assessing-ML-risks-of-VA-and-VASPs.html) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [Crypto regulatory affairs: OCC gives US banks go-ahead on riskless crypto transfers](https://www.elliptic.co/blog/crypto-regulatory-affairs-occ-gives-us-banks-go-ahead-on-riskless-crypto-transfers) - [The FATF Releases its Revised Virtual Asset Guidance](https://www.elliptic.co/blog/the-fatf-releases-its-revised-virtual-asset-guidance) - [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html) - [Money Laundering Offences | The Crown Prosecution Service](https://www.cps.gov.uk/prosecution-guidance/money-laundering-offences) - [Suspicious Activity Reports - National Crime Agency](https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-illicit-finance/suspicious-activity-reports) - [Report on Draft Financial Investigations (Northern Ireland) Order 2001](https://www.niassembly.gov.uk/assembly-business/committees/1998-2003/ad-hoc-committee-financial-investigation-ni-order/report/) - [Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Mltf-vulnerabilities-legal-professionals.html) - [Offences - Terrorism Act 2000](https://www.legislation.gov.uk/ukpga/2000/11/part/III/crossheading/offences) - [Solicitor client accounts - GOV.UK](https://www.gov.uk/government/publications/public-guardian-practice-note-opgs-approach-to-solicitor-client-accounts/solicitor-client-accounts) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-ireland-2017.html) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-ireland-2022.html) - [OCCRP](https://www.occrp.org/en/news/eu-faces-pressure-to-close-irish-alumina-loophole-after-russian-arms-link) - [European Commission Representation in Ireland](https://ireland.representation.ec.europa.eu/news-and-events/news/european-commission-calls-ireland-correctly-transpose-5th-anti-money-laundering-directive-2024-04-24_en) - [Elliptic](https://www.elliptic.co/country-guides/ireland) - [Council of the European Union](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [UK National Crime Agency](https://www.nationalcrimeagency.gov.uk/news/cross-border-arrests-in-international-money-laundering-investigation) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en) Coverage gaps fim-int-2026-07-10-G001: No substantive D4 Conflict Finance … fim-int-2026-07-10-G001: No substantive D4 Conflict Finance finding was located this cycle; Sahel conflict-mineral and DRC mining-sector coverage remain absent. [resolved] fim-int-2026-07-10-G002: Primary OFSI notice confirming the … fim-int-2026-07-10-G002: Primary OFSI notice confirming the Reg 17A(2) crypto-exchange designation action was not retrieved this cycle; sourcing rests on a single Tier-3 secondary report. [resolved] fim-int-2026-07-10-G003: Ireland's AMLD6/AMLR transposition … fim-int-2026-07-10-G003: Ireland's AMLD6/AMLR transposition legislation had not yet been drafted as of the most recent professional-services assessment, despite the July 2026 BO-provision deadline. [resolved] fim-int-2026-07-10-G004: Conflicting reporting on whether Ir… fim-int-2026-07-10-G004: Conflicting reporting on whether Ireland shortened the standard 18-month MiCA CASP grandfathering window relative to the EU-wide 1 July 2026 deadline was not resolved this cycle. [resolved] fim-int-2026-07-10-G005: No fresh cycle-specific FinCEN/FCA/… fim-int-2026-07-10-G005: No fresh cycle-specific FinCEN/FCA/EU AI Act compliance-technology guidance citation was located for D6 this cycle. [resolved] fim-int-2026-07-10-G006: PEP-classification and APP-fraud-as… fim-int-2026-07-10-G006: PEP-classification and APP-fraud-as-AML-feeder signals (UK PSR 2024 regime) had no supporting source this cycle. [resolved] fim-int-2026-08-05-G001: No independently retrieved gov.ie/D… fim-int-2026-08-05-G001: No independently retrieved gov.ie/Department of Finance primary source for the 18 June 2026 NRA/action-plan launch; relies on a single Tier-4 trade-press report. [resolved] fim-int-2026-08-05-G002: No direct EU Official Journal text … fim-int-2026-08-05-G002: No direct EU Official Journal text retrieved for the AMLR/AMLD6/AMLA timetable; relying on secondary legal commentary. [resolved] fim-int-2026-08-05-G003: No material Laos-specific signal id… fim-int-2026-08-05-G003: No material Laos-specific signal identified this cycle (Tier-D coverage check). [resolved] fim-int-2026-08-05-G004: No material Colombia-specific signa… fim-int-2026-08-05-G004: No material Colombia-specific signal identified this cycle (Tier-D coverage check). [resolved] fim-int-2026-08-05-G005: Compliance-technology (D6) coverage… fim-int-2026-08-05-G005: Compliance-technology (D6) coverage thin this cycle; no RegTech/AI-monitoring regulatory guidance development identified. [resolved] fim-int-2026-09-28-G001: Tier D jurisdiction watch (KH, LA, … fim-int-2026-09-28-G001: Tier D jurisdiction watch (KH, LA, MX, CO) not resolved this cycle; recorded as an honest gap rather than a null finding. [resolved] fim-int-2026-09-28-G002: D1 (Russian sanctions-evasion archi… fim-int-2026-09-28-G002: D1 (Russian sanctions-evasion architecture), D3 (enabler jurisdictions), D4 (conflict finance) and D6 (compliance technology) were not actively pursued this cycle given pooled cross-consumer search budget. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): The 2026 NRA itself was not directly retrieved this cycle; only secondary T3 legal-press reporting was consulted, so min_t1_per_instrument_met is not satisfied for the NRA claims. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary Department of Finance document for the National AML/CFT/CPF Strategy was not independently retrieved this cycle; the strategy launch rests on two T3 law-firm commentary sources. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): The text of Gambling Regulation Act 2024 s.230 and the full commencement order excluding it were not independently retrieved this cycle; status rests on a single T3 trade-press source. [resolved] fim-int-2026-10-04-G003: D1-D6 Tier-D jurisdiction collectio… fim-int-2026-10-04-G003: D1-D6 Tier-D jurisdiction collection (KH/LA/MX/CO) and non-IE standing-tracker content are out of scope for this single-JID union dispatch; this is a scope boundary, not a finding of no material change in those jurisdictions. [resolved] fim-int-2026-10-06-G001: CJA 2010 s.33A consolidation review… fim-int-2026-10-06-G001: CJA 2010 s.33A consolidation reviewed by research is current only to 1 August 2025; later instruments (S.I. 307/2026, S.I. 335/2026) have not been checked against the e-money CDD derogation before relying on it. [resolved] fim-int-2026-10-06-G002: The Irish trust beneficial-ownershi… fim-int-2026-10-06-G002: The Irish trust beneficial-ownership register access route may have changed following S.I. 440/2025 and S.I. 335/2026; only a secondary source (Ogier) was available, not the primary instruments themselves. [resolved] fim-int-2026-10-06-G003: No verbatim quoted text was admitte… fim-int-2026-10-06-G003: No verbatim quoted text was admitted for CJA 2010 s.40 third-party reliance scope or for the CBI AML/CFT Guidelines s.5.2.7 cross-reference this cycle. [resolved] fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (Enabler Jurisdictions) and D4 (Conflict Finance) Ireland-specific findings were not located this cycle given pooled search budget prioritisation. [resolved] fim-int-2026-10-12-G002: Tier-D watch jurisdictions (Cambodi… fim-int-2026-10-12-G002: Tier-D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) yielded no dedicated findings this cycle. [resolved] fim-int-2026-10-12-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-12-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): The 7 October 2026 EU sanctions expansion has not yet been confirmed via a formal Council Regulation/Decision text; requires re-verification against the Official Journal next cycle. [resolved] fim-int-2026-10-20-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-20-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively re-searched this cycle; the shared union search budget was prioritised toward Ireland-bound findings. [open] fim-int-2026-10-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-20-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Ireland-specific D1 Sanctions or D4 Conflict Finance findings were located this cycle, consistent with Ireland's chained/low-expected-floor DR research posture against its EEA parent layer. [open] fim-int-2026-10-20-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-20-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): The exact statutory instrument numbers for the two SIs underpinning the 10 November 2026 beneficial-ownership access-timeframe change were not independently confirmed this cycle. [open] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No dedicated search of Ireland's primary AML/CTF, sanctions or market-abuse instruments (Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended, Central Bank AML/CTF guidelines, Department of Finance sanctions notices) was run this cycle within budget. [open] FIM-GAP-001 (D2): Ireland's beneficial ownership register of… FIM-GAP-001 (D2): Ireland's beneficial ownership register of trusts remains flagged by the European Commission as inadequate in completeness and accessibility, an infringement opened in April 2024 that remained unresolved as of this baseline, ahead of the AMLR's directly-applicable BO rules taking effect. FIM-GAP-002 (D3): FATF's 2017 Mutual Evaluation found Irelan… FIM-GAP-002 (D3): FATF's 2017 Mutual Evaluation found Ireland had secured only guilty-plea money-laundering convictions with no convictions achieved after a full trial, a gap the 2022 follow-up report did not report as resolved, despite Ireland's status as a major international financial centre. FIM-GAP-003 (D1): Despite the scale of the Aughinish Alumina… FIM-GAP-003 (D1): Despite the scale of the Aughinish Alumina revelations (roughly $400 million of alumina reaching Russian smelters supplying sanctioned arms makers in 2024 alone), no sanctions listing, penalty, or licence action had been taken against the refinery or its supply chain as of this baseline; only a government review was opened. FIM-GAP-004 (D1): The designated authoritative NRA for Irela… FIM-GAP-004 (D1): The designated authoritative NRA for Ireland (Ireland AML Steering Committee, National Risk Assessment 2026) could not be directly retrieved and read in full during this research pass; its content is referenced by seed provenance only and requires primary-document verification in the next cycle. FIM-GAP-005 (D3): No standalone Central Bank of Ireland AML/… FIM-GAP-005 (D3): No standalone Central Bank of Ireland AML/CTF enforcement fine against a regulated financial institution was identified as publicly disclosed within the 18-month baseline window, despite a historical base rate of frequent AML fines (108 since 2006, totalling roughly €57 million) against Irish banks. ## Evidence #### Confidence-tiered claims Customers connected to EU Commission high-risk third countries, now including Russia (from 29 January 2026), Bolivia and BVI per Delegated Regulations 2026/46 and 2026/83 [[Source 1]](#sec-sources) Probable · 1 source Electronic-money CDD derogation applies only where instrument is non-reloadable or Ireland-only with €150 monthly limit; stored value ≤€150; goods/services only; no anonymous funding; monitored; no cash redemption over €50; no remote payment over €50. Excludes high-risk third-country customers and PEP (s.37) cases. [[Source 1]](#sec-sources) Probable · 1 source Minimum 5-year retention of records, extendable up to a further 5 years on Garda direction [[Source 1]](#sec-sources) Probable · 1 source Designated person must ascertain beneficial ownership information is entered in the relevant trust or Central Register of Beneficial Ownership before establishing a business relationship with in-scope corporate/trust customers; accounts limited to no-transactions basis until confirmed. [[Source 1]](#sec-sources) Probable · 1 source Reliance permitted only on listed relevant third parties (qualifying credit/financial institutions and listed professionals); excludes undertakings that are financial institutions solely via FX or payment services; reliance covers ss.33 and 35(1) but not s.35(3) ongoing monitoring; documents to be forwarded as soon as practicable after request; outsourcing providers/agents under s.40(6)-(7) fall outside the reliance concept with the EMI remaining liable. [[Source 1]](#sec-sources) Uncertain · 1 source 10 November 2026 [[Source 1]](#sec-sources) Probable · 1 source ML: moderate; TF/PF: low; first standalone PF threat assessment published [[Source 1]](#sec-sources) Probable · 1 source c.1,650 individuals and entities agreed by ambassadors, pending formal Council adoption [[Source 1]](#sec-sources) Probable · 1 source 12 authorised CASPs as of 7 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Deputy Governor Colm Kincaid said authorities should make it easier for scam victims to report offences and clarify who must repay them, framing fraud as the top financial-crime concern globally. [[Source 1]](#sec-sources) Probable · 1 source S.I. No. 307/2026 (European Union (Money Laundering and Terrorist Financing) (Administrative Sanctions) Regulations 2026) entered into force 30 June 2026, enabling AMLCU to impose administrative financial penalties on AMLCU-supervised TCSPs alongside existing criminal offences under the CJA 2010. [[Source 1]](#sec-sources) Probable · 1 source CBI confirmed on 12 October 2026 that it implements the ESMA guidelines specifying supervisory practices to prevent and detect insider dealing, unlawful disclosure and market manipulation involving crypto-assets under MiCA. [[Source 1]](#sec-sources) Probable · 1 source New statutory response-timeframe obligations for beneficial-ownership register access procedures under two implementing SIs take effect from 10 November 2026. [[Source 1]](#sec-sources) Probable · 1 source AMLA's public consultation on draft RTS for cross-border information exchange between Financial Intelligence Units closed 6 October 2026; final text not yet published. [[Source 1]](#sec-sources) Probable · 1 source AMLA held a public hearing on its draft Regulatory Technical Standards (RTS) for establishing a central AML/CFT database. [[Source 1]](#sec-sources) Probable · 1 source MiCA became applicable to CASPs in Ireland from 30 December 2024 [[Source 1]](#sec-sources) Probable · 1 source A new administrative financial-sanctions regime for the AMLCU, applying at least to TCSPs not supervised by the Central Bank or prescribed accountancy bodies, is expected to enter into force soon [[Source 1]](#sec-sources) Probable · 1 source Fined Cantor Fitzgerald Ireland Limited EUR 452,790 on 25 February 2025 for Article 16(2) MAR STOR-reporting failures (2017-2023), its 159th enforcement outcome [[Source 1]](#sec-sources) Probable · 1 source The Central Bank is designated as State competent authority for monitoring credit and financial institutions' AML/CFT compliance under Part 4 of CJA 2010 [[Source 1]](#sec-sources) Probable · 1 source An EU-wide EUR 10,000 cash-payment limit becomes applicable from 2027 as AMLR/6AMLD transposition bites [[Source 1]](#sec-sources) Probable · 1 source Individual holding >25% of capital, profits or voting rights of a company or partnership, or otherwise controlling management; fallback to senior managing officials where no natural person meets the threshold. [[Source 1]](#sec-sources) Probable · 1 source A designated person forming the opinion of a discrepancy between a company's RBO entry and its own CDD information must deliver a discrepancy notice to the Registrar. [[Source 1]](#sec-sources) Probable · 1 source Newly incorporated companies have 5 months from incorporation to file BO information; existing companies had until 22 November 2019; changes must be notified within 14 days. [[Source 1]](#sec-sources) Probable · 1 source Trustees of a relevant trust must register beneficial-ownership information with CRBOT within six months of the trust's creation, updating within 14 days of any change. [[Source 1]](#sec-sources) Probable · 1 source Failure to register a trust in CRBOT or report a discrepancy is an offence subject to a Class A fine (max EUR 5,000) on summary conviction. [[Source 1]](#sec-sources) Probable · 1 source A designated person who knows, suspects or has reasonable grounds to suspect ML/TF must report to FIU Ireland and Revenue as soon as practicable, and must not proceed with the transaction before the report is sent unless impracticable to delay. [[Source 1]](#sec-sources) Probable · 1 source A designated person who has made an STR must respond to requests for additional information from FIU Ireland or Revenue as soon as practicable. [[Source 1]](#sec-sources) Probable · 1 source It is an offence to disclose that an STR has been made or that an ML/TF investigation is taking place where disclosure is likely to prejudice an investigation; max EUR 5,000 fine or up to 5 years imprisonment on indictment. [[Source 1]](#sec-sources) Probable · 1 source A payment service provider must ensure a transfer of funds is accompanied by originator and beneficiary information; Central Bank must report any known/suspected PSP ML/TF involvement to Garda and Revenue. [[Source 1]](#sec-sources) Probable · 1 source From its application date, the recast Funds Transfer Regulation extends originator/beneficiary information requirements to crypto-asset transfers, replacing Regulation (EU) 2015/847. [[Source 1]](#sec-sources) Probable · 1 source Any person or entity holding funds or economic resources belonging to a designated person must freeze them, not deal with or release them absent an authorised derogation, and report the freeze to the Central Bank via the Sanctions Return Form. [[Source 1]](#sec-sources) Probable · 1 source Ireland enforces around fifty EU sanctions packages domestically through Statutory Instruments, with the Central Bank, DETE and a third body as competent authorities; VASPs recently added to designated-persons/obliged-entity scope. [[Source 1]](#sec-sources) Probable · 1 source A designated person must adopt internal policies, controls and procedures approved by senior management, and complete business-level and customer/transaction-level risk assessments, kept up to date. [[Source 1]](#sec-sources) Probable · 1 source A designated person must keep records evidencing CDD procedures and information obtained for each customer (and correspondent relationship under s.38) for 5 years after creation; extendable up to a further 5 years on direction. [[Source 1]](#sec-sources) Probable · 1 source Market operators, investment firms operating a trading venue, and persons professionally arranging/executing transactions must report suspicious orders and transactions (STOR) to the Central Bank without delay. [[Source 1]](#sec-sources) Probable · 1 source CASPs that operate a trading venue and persons professionally arranging/executing transactions in crypto-assets must report suspicious orders and transactions to the Central Bank without delay. [[Source 1]](#sec-sources) Probable · 1 source A body corporate or unincorporated body found liable for AML/CFT contravention under the Administrative Sanctions Procedure is liable to the greatest of EUR 10,000,000, twice the benefit derived, or 10% of turnover for the last complete financial year. [[Source 1]](#sec-sources) Probable · 1 source A dedicated Counter-Proliferation Financing Strategy 2026-2030 has been adopted following the 2026 National Risk Assessment, covering banks, credit unions, payment institutions, CASPs, investment firms, funds, accountants, solicitors, estate agents, gambling operators and TCSPs. [[Source 1]](#sec-sources) Probable · 1 source Over EUR 7 million laundered through money-mule accounts in the 12 months to June 2026; typical mule-account values EUR 5,000-10,000 per case. [[Source 1]](#sec-sources) Probable · 1 source No mandatory APP-fraud reimbursement scheme exists in Ireland; Central Bank expects banks to trace/recover funds and compensate victims where loss results from firm system failure, and has indicated support for a voluntary industry reimbursement arrangement. [[Source 1]](#sec-sources) Probable · 1 source