Some significant changes made in late 2018 to Irish AML legislation may have gone unnoticed. They need urgent attention as each designated entity is required, under Section 30A, to prepare a Business Risk Assessment. More on this in a subsequent blog.

The main changes introduced by the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act, 2018 are:

  1. Each designated entity is to carry out and document a Business Risk Assessment of the business/firm itself;
  2. Identify locally based Politically Exposed Persons (PEPs) and treat them (as well as defined family members) as high risk;
  3. Enhance the existing requirements for carrying out customer due diligence and require the maintenance of more detailed training records;
  4. For those businesses that deal in goods sold for cash, the threshold when AML identification of the customer is required, now starts at €10,000 (rather than €15,000 heretofore);
  5. The creation of the central register of beneficial owners in each EU country. In Ireland, this will be kept at the CRO. This register will be formally launched later in 2019. Watch for updates on the new launch date at

Accountancy firms will need a set of procedures and checklists to deal with the new law. Our new fully updated AML Policies & Procedures Manual is now available here. It is fully updated for the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which came into force on 26 November 2018. It retails at €150+VAT.

For on-demand webinars on AML and developments in Investment Property Accounting, FRS 105, Common Errors in FRS 102 Accounting and the latest on FRS 105 and company law, visit our online webinar training website. Once viewing is completed, customers will receive a CPD Certificate confirming their learning.