The AMLR, explained for Irish firms
From 10 July 2027, Regulation (EU) 2024/1624 — the AMLR — replaces the substantive AML rulebook Irish designated persons have followed under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010). It is a directly applicable EU regulation: no Irish transposition, no local variations. This page sets out what it is, when it lands, and what actually changes for your firm.
AMLR, AMLD6 and AMLAR do three different jobs
The 2024 EU AML package is three instruments, not one. Your firm’s day-to-day obligations sit in the AMLR. The other two change the machinery around you.
AMLR
Regulation (EU) 2024/1624
The substantive rulebook: customer due diligence, beneficial ownership, internal controls and reporting obligations for obliged entities. As a regulation it is directly applicable in all 27 member states — there is no Irish transposition to wait for.
Applies 10 July 2027 · football clubs and agents from 10 July 2029
AMLD6
Directive (EU) 2024/1640
The machinery around the rulebook: national supervisors, FIU powers, beneficial-ownership registers and cross-border cooperation. As a directive, Ireland transposes it into national law.
General transposition due 10 July 2027
AMLAR
Regulation (EU) 2024/1620
Creates AMLA — the EU Anti-Money Laundering Authority in Frankfurt. AMLA is already producing the technical standards and guidelines that will shape how the AMLR is supervised in practice.
AMLA operational since 1 July 2025
Don’t conflate them. The AMLR is the rulebook your firm follows. AMLD6 rewires supervision and registers at national level. AMLAR created the supervisor. Reading the three interchangeably is the quickest way to misread your obligations — and much commentary does exactly that.
Five dates that matter
2024
EU AML package adopted
The AMLR, AMLD6 and AMLAR are adopted as a single package.
1 July 2025
AMLA operational
The EU Anti-Money Laundering Authority starts work in Frankfurt.
~10 July 2026
Technical standards land
The main batch of AMLA technical standards and guidelines is due — the detail behind the rulebook.
10 July 2027
The AMLR applies
The single rulebook applies directly across the EU. Ireland’s AMLD6 transposition is due the same day.
10 July 2029
Football in scope
Football clubs and agents become obliged entities.
The headline changes for your firm
You are not starting AML from zero — Irish firms have been designated persons for over a decade. But the thresholds, roles and record-keeping rules your programme was built around change on 10 July 2027.
From “designated person” to “obliged entity”
Same firms, new label. The shift in language signals the shift in legal basis — from Irish transposition to a directly applicable EU regulation.
Designated person
The term Irish law uses under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Your current policies, supervisor correspondence and guidance are written in this language.
Obliged entity
The AMLR’s term. Expect supervisor guidance, templates and inspection language to switch over as the regulation applies. Your refreshed policies and BWRA should use it — CompliDesk’s templates already do.
Who supervises whom
AML supervision in Ireland is sector-by-sector. Know your supervisor — it shapes the guidance you follow, the inspections you face and the registrations you hold.
| Sector | AML supervisor |
|---|---|
| Estate agents, letting agents, auctioneers, property management | PSRA — Property Services Regulatory Authority |
| Solicitors | Law Society of Ireland |
| Accountants, auditors, tax advisers (members of a body) | Designated accountancy bodies — Chartered Accountants Ireland, ACCA, CPA Ireland |
| TCSPs, high-value goods dealers, unaffiliated accountants and tax advisers | AMLCU — Anti-Money Laundering Compliance Unit, Department of Justice |
| Banks, funds, payments, insurers, CASPs | Central Bank of Ireland |
How CompliDesk gets you ready
CompliDesk Ireland is built to the AMLR from day one — not retrofitted from the old directives. The platform launches well before 10 July 2027; readiness services and free early access are available now. Built and battle-tested through Australia’s 2026 AML reform with real paying firms.
Policy pack + BWRA generator
Refresh your Business-Wide Risk Assessment (BWRA) and rebuild your policies against the AMLR — with compliance manager and compliance officer role designation built in.
Onboarding, CDD and screening
Client onboarding with KYC/KYB identity verification (Didit) and sanctions & PEP screening via OpenSanctions — EU consolidated list, UN and PEP data — plus cash-rule warnings at the €10,000 cap and the €3,000 occasional-cash CDD trigger.
STR, RBO and CRO workflows
An STR builder with goAML-compatible XML export and a dual-submission tracker for goAML and Revenue ROS. RBO extract workflow with discrepancy logging, and CRO company lookup.
Records, training, audit trail
Record retention with 5-years-then-delete built in, a staff training log and a full audit trail. Data hosted in the EU — AWS eu-west-1 (Dublin).
Want a structured starting point? Download the free AMLR Readiness Checklist for Irish Firms (PDF) — thresholds, roles, reporting and record-keeping in one practical document.
Get your firm AMLR-ready before the rush
See how CompliDesk maps your CJA 2010 programme to the AMLR — or join the waitlist and lock in founding-member pricing before launch.