17/08/2026
Insights Blog

On 13 August 2026, the Tánaiste and Minister for Finance Simon Harris TD, launched Ireland’s first National Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing Strategy (the Strategy).  The Strategy sets out the Government’s approach to combating financial crime over the period 2026 to 2030 and follows publication of the 2026 National Risk Assessment on Money Laundering, Terrorist Financing and Proliferation Financing (NRA). It is intended to deliver a coordinated, whole-of-government approach to preventing the misuse of Ireland’s financial system for criminal purposes.

The Strategy is structured around three pillars: policy and oversight; safeguarding and monitoring; and investigation and enforcement. A particular driver for a number of the actions, particularly national coordination and international cooperation, is preparations for Ireland’s next Financial Action Task Force (FATF) Mutual Evaluation, expected in 2028.

For further detail on the NRA and accompanying action plan, see our earlier insights here: Ireland’s AML/CFT Action Plan: 2026 – 2027 | Arthur Cox LLP

Key priorities

 The Strategy identifies five overarching priorities:

  1. strengthening national coordination through the Anti-Money Laundering Steering Committee;
  2. improving the identification and assessment of financial crime risks through enhanced data collection and intelligence analysis;
  3. delivering a stronger, EU aligned regulatory framework, including transposition of the Sixth Anti-Money Laundering Directive and the Transfer of Funds Regulation and effective implementation of the Anti-Money Laundering Regulation;
  4. building AML capability across government, law enforcement, regulators and the public and private sectors; and
  5. enhancing international cooperation, including engagement with the new EU Anti-Money Laundering Authority (AMLA).

Key reforms

From a business perspective, the most notable reforms highlighted in the Strategy include:

  • strengthened AML requirements for crypto-assets and crypto-asset transfers, aimed at making it more difficult to move illicit funds anonymously;
  • implementation of the EU’s new AML framework, including transposition of the Sixth Anti-Money Laundering Directive and related legislation;
  • expanded beneficial ownership transparency measures, including mandatory disclosure of the ultimate beneficial owners and controllers of all Limited Partnerships;
  • enhanced information-sharing and financial intelligence capabilities across Government departments, law enforcement agencies, Revenue, FIU Ireland, the Central Bank and financial institutions;
  • increased focus on the impact of emerging technologies (including AI) sanctions evasion and emerging financial crime threats;
  • strengthened supervision of sectors regarded as presenting elevated money laundering risks (for example, establishing an industry standard on accepting crypto-related activities as a source of funds in the gambling sector); and
  • confirmation that the Funds Sector 2030 transparency recommendations for Irish section 110 special purpose entities will be implemented, including a Revenue power to publish a list of section 110 entities and a proposed Legal Entity Identifier requirement for entities using that regime.

Beneficial ownership developments

Alongside the Strategy, the Department of Finance has recently finalised two statutory instruments (SIs) (here and here) implementing aspects of the Sixth Anti-Money Laundering Directive relating to beneficial ownership registers. These measures apply respectively to Ireland’s corporate and trust beneficial ownership registers and form part of the wider EU reforms designed to increase transparency and strengthen access to beneficial ownership information.

In broad terms, the new rules expand the categories of public authorities permitted to access beneficial ownership information, including AMLA, the European Public Prosecutor’s Office, Europol and Eurojust. They also introduce a more formal certificate-based process for persons seeking access on the basis of a “legitimate interest”, with certificates capable to remaining valid for up to three years (certain categories of individual will be deemed to have a legitimate interest). The new access procedures bring defined response timelines and appeal rights. These reforms introduce a more structured and formalised process for access to register information, reflecting the approach mandated under the EU’s new AML framework.

Comment

The Strategy provides the clearest indication to date of the Government’s AML priorities for the remainder of the decade. It confirms a continued focus on implementation of the EU AML package, increased corporate transparency, enhanced information sharing and a more coordinated approach to supervision and enforcement.

In the near term, firms should note that the new beneficial ownership access procedures under the two aforementioned SIs bring defined statutory response timeframes into effect from 10 November 2026, and more broadly, preparations for Ireland’s next FATF Mutual Evaluation in 2028 are likely to shape the pace and prioritisation of reform through the remainder of this decade.

With thanks to Keela Farnon for her contribution.