Auctioneers under the AMLR: what changes at the rostrum

Auction work has a timing problem that most AML guidance ignores. When the hammer falls, a binding contract exists in seconds — there is no leisurely onboarding window in which to complete customer due diligence. If you are a PSRA-licensed auctioneer in Ireland, you have managed that tension under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 for years. From 10 July 2027, the EU's AML Regulation (the AMLR, Regulation (EU) 2024/1624) replaces the substantive rulebook, and several of its changes land directly on the rostrum: lower CDD thresholds, a cash trigger at €3,000, and a hard €10,000 cap on cash payments.

Here is what changes, and how to run a sale room that stays on the right side of it.

Who supervises auctioneers, and does that change?

Auctioneers are licensed and AML-supervised by the PSRA, the Property Services Regulatory Authority, which acts as the AML competent authority for estate agents, letting agents, auctioneers and property management firms. That does not change on 10 July 2027. What changes is the rulebook the PSRA applies: the AMLR is a directly applicable EU regulation, so its CDD rules, cash rules and record-keeping requirements take effect in Ireland without a transposing Act. Irish law currently calls you a "designated person"; the AMLR calls you an "obliged entity". Expect both terms in guidance through the transition.

What are the new thresholds that matter in a sale room?

Three numbers should be pinned to the wall of every auction house before July 2027:

• €10,000 — occasional transaction CDD. The threshold for applying customer due diligence to occasional transactions drops from €15,000 to €10,000, whether paid in one go or in linked operations.
• €3,000 — occasional cash CDD. Occasional cash transactions of €3,000 or more trigger limited CDD. A cash buyer at a modest lot can now put you in CDD territory.
• €10,000 — the cash cap. An EU-wide cap on cash payments for commercial transactions applies at €10,000, across single or linked payments. This is not a CDD trigger; it is a limit on accepting the cash at all. A buyer cannot lawfully split a €14,000 cash payment into two instalments to get around it — linked operations count together.

If your terms and conditions of sale, your clerk's procedures or your payment desk practices are keyed to the old €15,000 figure, they will be wrong on day one.

How do you do CDD when the hammer creates the contract?

The practical answer most auction businesses reach is to move due diligence before the sale, not after it. That usually means:

• Bidder registration. Require identity information at registration, before a paddle is issued, so that CDD is substantially complete before anyone can bid.
• Vendor CDD at consignment. Identify and verify vendors when lots are consigned, including beneficial ownership where the vendor is a company — and for corporate vendors, obtain an extract from the Register of Beneficial Ownership before the business relationship begins, recording any discrepancy you find.
• Conditional release. Make release of the lot and completion of the sale conditional on CDD being finished, so an unresolved verification never becomes an unresolvable one.

A purely hypothetical example: a new bidder registers by phone on the morning of a sale, wins a lot at €11,500 and arrives to pay in cash. Under the AMLR that payment cannot be accepted in cash at all, and the transaction requires full CDD. A registration process that captured identity up front, and a payments policy that says card or transfer above the cap, turns that from a crisis into a routine.

What about suspicious activity at auction?

The reporting mechanics do not change. Suspicious Transaction Reports remain dual-reported in Ireland: to FIU Ireland via the goAML portal and to the Revenue Commissioners via ROS. Ireland has no threshold transaction reporting regime — there is no form to file simply because a sale was large. What matters is suspicion: a bidder indifferent to price, unusual third-party payments, or a vendor evasive about how they came to own the goods. Train your rostrum and front-of-house staff to recognise and escalate, and keep the training log current.

What to do now

1. Update your conditions of sale and payment procedures for the €10,000 cash cap and the €3,000 occasional-cash CDD trigger.
2. Rebuild bidder registration so identity capture happens before a paddle is issued.
3. Add vendor CDD — including beneficial ownership and RBO extracts for corporate vendors — to your consignment process.
4. Replace any €15,000 references in policies and training materials with the AMLR thresholds.
5. Decide who holds the compliance manager and compliance officer roles the AMLR prescribes, and record it.
6. Confirm your goAML and ROS registrations are live, and refresh staff training on escalation.
7. Refresh your business-wide risk assessment to reflect auction-specific risks: cash, speed, and one-off buyers.

Where CompliDesk fits

CompliDesk Ireland builds the AMLR's thresholds into your client and transaction workflows, so a €3,000 cash payment or a €10,000 cap breach is flagged before it happens, not discovered afterwards. If you are unsure which of your auction activities are in scope, start with our scope checker.