Introduction
The Department of Finance (DoF) has published Ireland’s third National Risk Assessment on Money Laundering (ML), Terrorist Financing (TF) and Proliferation Financing (PF) (the NRA), together with a new 30‑Point Action Plan (the Action Plan) designed to strengthen Ireland’s response to financial crime.
The NRA was developed by Ireland’s Anti-Money Laundering Steering Committee (AMLSC) and provides a consolidated, national-level analysis of ML, TF, and PF risks. The purpose of the NRA is to provide a foundation for policy and decision-making and inform the development of Ireland’s legal, regulatory and enforcement frameworks.
Key Findings
The NRA notes that Ireland is an open economy, ranks among the top five exporters of financial services in the EU, and has been identified by the IMF as one of 29 jurisdictions with a systemically important financial sector. In this context, five financial services sectors were selected for in-depth assessment due to their scale, complexity, and exposure to ML, TF, and PF risks; Retail Banks, Non-Retail Banks, Funds, Virtual Asset Service Providers (VASPs) and Payment Institutions (PIs) / Electronic Money Institutions (EMIs). Separate higher-level reviews were also conducted for seven other financial services sectors with a view to informing future prioritisation and supervisory engagement.
The key findings highlight sectoral risks, with the ML risk in traditional Retail Banks, Digital Banks, crypto-assets, EMIs, PIs which are money remitters and non-securitisation Special Purpose Entities (SPEs) assessed as being very significant, and the TF risk in traditional Retail Banks, Digital Banks, crypto-assets, and PIs which are money remitters also being assessed as very significant. These heightened exposures stem from a variety of sources, including significant international linkages, the nature of the products and services available in the sector, and the scale and importance of the sectors in Ireland.
Action Plan
The Action Plan translates these findings into a focused programme of work for the following 18 months.
The following action points are of particular relevance to the financial services sector:
| Action | Timeline
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The CBI will enhance data collection, undertake targeted analysis of sectors and products, and provide structured feedback to sectors and firms. Firms will be expected to incorporate this feedback into their business wide risk assessments and AML/CFT systems and controls.
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Q3 2027 |
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The CBI will develop its understanding of emerging technologies (including AI), employ ‘SupTech’ and set out its expectations to firms. As above, firms will be expected to incorporate this feedback.
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Q1 2027 |
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In the gambling sector, (i) casinos will have a more robust regulatory framework, (ii) Private Members Clubs will be made subject to mandatory licensing requirements, (iii) providers will be required to adopt a ‘closed loop’ system, whereby payments to customers are made using the same payment account used for depositing funds, and (iv) an industry standard will be developed relating to the acceptance of crypto.
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Q2 2027 |
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The DoF will examine ways to enhance interoperability between the State’s beneficial ownership registers.
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Q1 2027 |
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Revenue will assess the impact of proposed changes to the range of trusts required to provide information to the Central Register of Beneficial Ownership of Trusts (CRBOT).
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Q1 2027 |
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The DoF will introduce mandatory disclosure of the ultimate beneficial owners and controllers of all Limited Partnerships (LPs).
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Q2 2027 |
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As regards LPs, the DoF will examine options for restricting / prohibiting general partners based in secrecy jurisdictions, and the use of corporate entities as general partners.
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Q4 2026 |
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The Department of Enterprise, Tourism and Employment (DETE) will implement a process to independently verify information submitted to the CRO.
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Q2 2027 |
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DETE will review the audit exemption criteria under the Companies Act 2014 with a view to ensuring appropriate financial transparency and oversight.
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Q2 2027 |
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The DoF will lead discussions re: a mandatory registration requirement with FIU Ireland for persons with reporting obligations.
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Q4 2026 |
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Powers of pecuniary sanction will be provided to all AML/CFT supervisors.
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Q2 2027 |
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The DoF will introduce legislation to implement the Funds Sector 2030 transparency recommendations for SPEs.
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Q4 2027 |
Ongoing Workstreams
In parallel, the NRA highlights the following ongoing workstreams:
- Beneficial ownership: work is ongoing to strengthen ML/TF oversight through improvements in the operation of Ireland’s three beneficial ownership registers. Following the transposition of AMLD6, the registrars will have additional data verification powers. Furthermore, work is ongoing to connect the registers to the Beneficial Ownership Registers Interconnection System (BORIS), a central EU platform that will facilitate cross border information sharing between competent authorities and designated bodies.
- Limited Partnerships: the Registration of Limited Partnerships and Business Names Bill is being progressed through the Oireachtas, and will enhance the legislative framework governing LPs.
- TSCPs: legislation establishing an administrative financial sanctions regime for the Anti-Money Laundering Compliance Unit of the Department of Justice, one of the supervisors of the sector, is expected to enter into force by mid-2026.