CDD thresholds under the AMLR: €15,000 down to €10,000, and the €3,000 cash trigger

If your firm's client-onboarding procedures mention a €15,000 threshold for occasional transactions, put a date in your diary: 10 July 2027. That is the day Regulation (EU) 2024/1624 (the AMLR) starts to apply across the EU, and the day that figure becomes wrong.

The AMLR is a directly applicable EU regulation — the "single rulebook." It does not need an Irish act to bring it into force, and it replaces the substantive customer due diligence (CDD) rules your firm has been applying as a designated person under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Two of the most practical changes sit in the threshold numbers: the general occasional-transaction trigger drops from €15,000 to €10,000, and a new €3,000 trigger applies to occasional transactions in cash.

This post explains what each threshold does, who it catches, and what to change in your procedures before the date.

The thresholds at a glance

Two clarifications. First, an "occasional transaction" is one for a client with whom you have no established business relationship — a one-off. Ongoing clients get full CDD regardless of transaction size; the thresholds only matter for one-offs. Second, thresholds apply to linked operations as well as single transactions, so a payment split into smaller pieces does not escape the trigger.

€15,000 down to €10,000: a wider net for one-off work

The drop from €15,000 to €10,000 sounds modest, but it changes who walks through your CDD process. One-off engagements between €10,000 and €15,000 — a once-off tax engagement, a standalone company formation — that previously sat under the threshold will now require customer due diligence: identifying and verifying the client, and understanding beneficial ownership where relevant.

The AMLR also changes the vocabulary. Irish law calls you a "designated person"; the AMLR calls you an "obliged entity." Same firm, new rulebook — your written procedures should use the AMLR's terms and numbers once it applies.

The practical risk here is not the new number itself. It is the old number surviving in your documents. Most Irish firms have AML policies written years ago under the CJA 2010 regime, often in Word documents that reference €15,000 explicitly. If a supervisor — the PSRA for property services firms, the Law Society of Ireland for solicitors, your designated accountancy body (Chartered Accountants Ireland, ACCA or CPA Ireland) for accountants, the AMLCU for TCSPs, or the Central Bank of Ireland for financial firms — reviews your file after 10 July 2027 and finds a €15,000 trigger still in your procedures, that is an immediate, visible gap.

The €3,000 cash trigger: new, and easy to miss

The genuinely new obligation is this: an occasional transaction of €3,000 or more in cash triggers limited CDD.

The word "limited" matters. This is not the full CDD process required at €10,000; it is a lighter-touch check aimed at cash specifically. But it is still a trigger your front-line staff must recognise in the moment — your procedures need a step that fires at that point.

Who feels this most? Any firm that ever takes meaningful cash from non-regular customers. High-value goods dealers are the obvious case, but auctioneers, letting agents collecting cash deposits, and practices that occasionally accept cash fees should all check whether a €3,000 cash payment could plausibly cross their counter.

A clearly hypothetical example: suppose a walk-in customer, not an existing client, wants to buy an item for €4,200 and offers cash. Under the AMLR, that purchase sits below the €10,000 general threshold, so full occasional-transaction CDD is not triggered — but it is above €3,000 in cash, so the limited cash CDD trigger fires. Your staff need to know that, and your file needs to show it happened.

The €10,000 cash cap sits alongside these rules

Separate from the CDD triggers, the AMLR introduces an EU-wide cap of €10,000 on cash payments for commercial transactions, covering single or linked operations. It is directly applicable, so it applies in Ireland without any Irish implementing act.

The interaction is worth spelling out for staff: cash of €3,000 up to the €10,000 cap is permitted but triggers limited CDD; cash at or above €10,000 for a commercial transaction is simply not allowed. Your procedures should treat these as two distinct rules — a check and a stop — rather than blending them into one vague "be careful with cash" line.

One thing that does not change: Ireland has no threshold transaction reporting regime. Crossing €3,000 or €10,000 in cash is not, by itself, something you report to FIU Ireland. Suspicious Transaction Reports remain suspicion-based, dual-reported to FIU Ireland via goAML and to the Revenue Commissioners. Do not let anyone in your firm confuse a CDD trigger with a reporting trigger.

CASPs: the €1,000 outlier

For completeness: crypto-asset service providers face CDD from €1,000 under the AMLR — a far lower trigger than other sectors. If your firm is a CASP, or serves clients transacting through one, the general thresholds above are not your benchmark. CASPs are supervised by the Central Bank of Ireland.

What to do now

1. Find every place a threshold number appears in your firm — AML policy, CDD procedure, onboarding checklists, staff training slides, engagement letter templates. List them.
2. Mark each €15,000 reference for replacement with €10,000, effective 10 July 2027, and add the €3,000 occasional-cash trigger wherever cash can realistically arrive.
3. Add the €10,000 cash cap as a hard stop in any procedure that touches payment acceptance, and make the cap-versus-trigger distinction explicit.
4. Decide who checks for linked transactions — split payments that together cross a threshold — and write that step down.
5. Brief front-line staff. Thresholds fail at the counter or the inbox, not in the policy binder. A one-page cheat sheet beats a fifty-page manual here.
6. Fold the new numbers into your next Business-Wide Risk Assessment refresh, so your documented risk picture and your operational triggers say the same thing.
7. Diarise a re-check against the final published guidance before July 2027 — supervisor expectations are still taking shape as AMLA standards land.

The source text is Regulation (EU) 2024/1624 itself, available on EUR-Lex, and AMLA's technical standards and guidelines are published at amla.europa.eu as they arrive.

Where CompliDesk fits

CompliDesk Ireland is built to the AMLR's numbers from day one — its client and transaction workflows flag the €10,000 threshold, the €3,000 occasional-cash trigger and the €10,000 cash cap automatically, so your staff do not have to hold the rulebook in their heads. See the AMLR explainer for the full picture of what changes on 10 July 2027.