Ireland published its first National Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing Strategy on 13 August 2026. The Strategy sets the State’s direction for preventing, detecting and enforcing financial crime over the period 2026 to 2030.
For banks and other financial institutions, solicitors, accountants, trust and company service providers, estate agents, gambling businesses and high-value goods dealers, the publication matters. It does not, by itself, make every proposed measure an immediate legal obligation. It does, however, show where Irish legislation, supervision and enforcement are going next.
The Strategy is a whole of government programme prepared by Ireland’s Anti-Money Laundering Steering Committee. It is informed by the 2026 National Risk Assessment and is intended to coordinate policy, supervision, intelligence, investigation and enforcement across State bodies.
Its scope is broader than conventional money-laundering compliance. Alongside AML and counter-terrorist financing, it places specific emphasis on countering proliferation financing: the provision or movement of funds or assets that support the proliferation of weapons of mass destruction, including related materials and delivery systems.
The Strategy is built around five goals:
· stronger national coordination;
· better risk assessment and understanding;
· an effective and evidence-led regulatory framework;
· capacity building and private-sector outreach; and
· deeper international cooperation.
1. Implementation of the new EU AML framework
Ireland is preparing to transpose the Sixth Anti-Money Laundering Directive and align its national system with the EU Anti-Money Laundering Regulation and the new EU Anti-Money Laundering Authority, AMLA. This is expected to require amendments to the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 and supporting statutory instruments.
National authorities are also examining how the new EU framework will affect designated non-financial businesses and professions, including legal and accountancy practices.
2. Greater beneficial-ownership transparency
The Strategy anticipates strengthened beneficial-ownership registers for companies, trusts and certain financial vehicles. The Department of Finance also intends to seek mandatory disclosure of the ultimate beneficial owners and controllers of all limited partnerships.
For advisers, this reinforces a familiar but critical point: identifying the immediate shareholder, partner or corporate member may not be enough. The analysis must reach the natural persons who ultimately own or control the structure and must address inconsistencies in the evidence obtained.
3. Better STR data and possible FIU registration
The State plans to improve FIU Ireland’s suspicious transaction reporting toolkit and its analytical capability. The Department of Finance will also consider whether persons with reporting obligations should be required to register with FIU Ireland.
That signals greater attention to the completeness, timeliness and usefulness of suspicious transaction reports. A defensive or formulaic report will not necessarily meet the underlying objective of supplying actionable financial intelligence.
4. More data-led supervision and enforcement
The Central Bank is expected to expand sector-by-sector risk data collection, targeted analysis and supervisory feedback. Competent authorities are also expected to review their risk-based supervisory approach annually and align their resources and inspection intensity with current threats.
The Strategy additionally supports closer information-sharing between supervisors and law-enforcement bodies on money laundering, terrorist financing, sanctions evasion and the quality of firms’ controls.
5. Focus on technology, crypto-assets and sanctions evasion
Regulated firms are expected to keep their frameworks current as criminals exploit artificial intelligence, digital financial services, crypto-assets, money mules and complex international networks. The Central Bank is expected to communicate more detailed expectations on governance, risk management and technology-enabled controls.
The Strategy also points to stronger mechanisms for sharing information on sanctions-evasion risk and to measures intended to implement relevant United Nations Security Council resolutions without delay.
The Strategy is not merely an aspirational policy document. It is linked to Ireland’s 2026 National Risk Assessment, a separate priority action plan and preparations for Ireland’s FATF mutual evaluation in 2028. Those processes place emphasis not only on whether laws and policies exist, but also on whether they work effectively in practice.
The practical consequence is likely to be more evidence-led supervision. A designated person may increasingly be expected to demonstrate:
· how its business wide risk assessment reflects the risks relevant to its sector, clients, services and delivery channels;
· how customer and beneficial owner information is independently verified;
· how source of funds and, where appropriate, source-of-wealth enquiries are calibrated to risk;
· how sanctions, proliferation-financing and crypto-related risks are assessed;
· how unusual activity is escalated, documented and reported; and
· how training, monitoring and governance produce effective outcomes rather than a paper-only compliance system.
1. Review the 2026 National Risk Assessment against the organisation’s current business-wide risk assessment and record the outcome.
2. Map the Strategy’s priority risks to client onboarding, beneficial-ownership checks, source-of-funds enquiries, sanctions screening, ongoing monitoring and suspicious-transaction reporting.
3. Identify higher-risk services and structures, including trusts, limited partnerships, company formations, cross-border arrangements, crypto-derived wealth and transactions involving complex or opaque ownership.
4. Test a sample of recent files to establish whether the written policy is being followed and whether the file records explain the decisions made.
5. Confirm that escalation and reporting procedures are understood by fee earners and frontline personnel, not only by the MLRO or compliance function.
Create a legislative and regulatory change log covering 6AMLD, the AML Regulation, AMLA standards and forthcoming Irish implementing measures.
6. Prepare an evidence pack showing the risk assessment, policies, training, monitoring, remediation and senior-management oversight available for inspection.
The correct response is not to apply maximum due diligence to every customer. Irish and EU AML frameworks are risk-based. Controls should be proportionate to the assessed risk and sufficiently documented to allow another person – including a regulator or inspector – to understand why a decision was reasonable at the time.
The immediate task is therefore one of readiness: understand the direction of travel, identify gaps and improve the quality of evidence supporting the organisation’s AML decisions.
Sherwin O’Riordan advises designated persons on Irish AML compliance, governance and regulatory readiness. We can assist with business-wide risk assessments, policies and procedures, beneficial-ownership and source-of-funds frameworks, staff training, file reviews, inspection preparation and remediation programmes.
To discuss how Ireland’s new AML strategy may affect your organisation, contact our AML and regulatory team today
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