If your firm is a designated person in Ireland — an accountancy practice, a solicitors' firm, a PSRA-licensed estate or letting agent, or a TCSP — your AML obligations currently come from the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended in 2018 and 2021. You have probably lived under it for years, and your policies, risk assessment and client onboarding checklists were written with it in mind.
On 10 July 2027, the substantive rulebook changes. Regulation (EU) 2024/1624 (the AMLR) is a directly applicable EU regulation — it does not need an Irish transposing Act to take effect. From that date, the detailed rules on customer due diligence, beneficial ownership, internal controls and record-keeping come from the AMLR itself. Alongside it, Directive (EU) 2024/1640 (AMLD6) reshapes the institutional layer — supervisors, FIU powers and beneficial-ownership registers — and Regulation (EU) 2024/1620 has created AMLA, the EU Anti-Money Laundering Authority in Frankfurt, operational since 1 July 2025.
This post puts the two regimes side by side so you can see, in practical terms, what a CJA 2010-era compliance programme needs to change.
First, the language changes
Irish law calls regulated firms "designated persons". The AMLR calls them "obliged entities". Expect to see both terms in supervisor guidance through the transition. The concept is the same, but your policies and training materials should start using the AMLR terminology alongside the familiar Irish one.
Your supervisor itself does not change on day one. Under the current framework, that means the Central Bank of Ireland for banks, funds, payments firms, insurers and CASPs; the Law Society of Ireland for solicitors; the designated accountancy bodies (Chartered Accountants Ireland, ACCA, CPA Ireland and others) for their member firms; the PSRA for estate agents, letting agents, auctioneers and property management; and the AMLCU in the Department of Justice for TCSPs, high-value goods dealers and unaffiliated accountants or tax advisers. AMLD6 governs how national supervision is organised going forward, and AMLA will drive convergence in how those supervisors work — but you should keep dealing with the supervisor you know.
The headline comparison
| Area | CJA 2010 world (today) | AMLR world (from 10 July 2027) |
|---|---|---|
| Legal source | Irish Act — CJA 2010, as amended | Directly applicable EU regulation — Regulation (EU) 2024/1624 |
| Terminology | Designated persons | Obliged entities |
| Occasional transaction CDD | Threshold of €15,000 | Drops to €10,000 |
| Occasional cash transactions | No equivalent stand-alone trigger | Limited CDD from €3,000 in cash |
| Cash payments | No EU-wide cap | €10,000 cap on cash for commercial transactions, single or linked |
| Beneficial ownership | 25% test under the existing framework | Harmonised EU-wide at 25% or more, direct or indirect; the Commission may set a lower threshold (15% or lower) for high-risk sectors by delegated act after a review due by 2029 |
| Compliance roles | MLRO and general management responsibility | Prescribed roles: a board-level compliance manager plus a compliance officer of sufficiently high standing |
| High-net-worth clients | Risk-based EDD, no fixed wealth test | EDD where assets handled are €5m+ and the client's total wealth is €50m+ (AMLA guidance on the €50m test is due by 10 July 2027) |
| FIU information requests | No harmonised EU deadline | Answered within 5 working days, shorter for some categories |
| Records | Retention obligations under the Act | Retain 5 years, then delete |
| Electronic identification | Not expressly framed around eIDAS | eIDAS-aligned electronic identification expressly recognised for identity verification |
A few of these deserve a closer look.
CDD thresholds: your onboarding triggers move
The threshold for applying CDD to occasional transactions drops from €15,000 to €10,000. On top of that, occasional cash transactions of €3,000 or more trigger limited CDD, and crypto-asset service providers apply CDD from €1,000. If your procedures, staff training or practice-management prompts are keyed to €15,000, they will be wrong on 10 July 2027. This is one of the simplest changes to make and one of the easiest to miss, because the number is usually buried in a procedures document nobody has opened since it was written.
The €10,000 cash cap for commercial transactions is a separate rule again — it is a limit on accepting cash at all, not a CDD trigger, and it applies to single or linked operations. Firms that occasionally take large cash payments need a policy answer before the date, not after.
Roles: from "an MLRO" to a prescribed structure
The AMLR prescribes two roles: a compliance manager at board level and a compliance officer of sufficiently high standing. From 10 July 2027 the compliance officer also becomes responsible for implementing targeted financial sanctions. For a small Irish firm where one principal has informally worn the MLRO hat for years, this means formally designating who holds each role, recording it, and making sure the sanctions responsibility is understood — not just assumed.
What does not change: Irish reporting mechanics
The AMLR replaces the substantive rulebook, but Irish reporting plumbing carries on. 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, and the AMLR does not introduce one. Your RBO duties also continue: since April 2021, designated persons must obtain an extract from the Register of Beneficial Ownership before entering a new business relationship and report discrepancies between the register and what CDD reveals.
Scope: check whether more of your work is caught
The AMLR widens who is in scope. Notable additions include crowdfunding providers, traders in high-value and luxury goods above thresholds (precious metals and stones dealers remain in scope), CASPs fully aligned with MiCA, and — significant for property firms — letting agents for tenancies with monthly rent of €10,000 or more. Football clubs and agents follow from 10 July 2029. If your firm sits near a boundary, work through it now rather than in June 2027 — our scope checker is a quick starting point.
What to do now
- Pull out your current AML policies and mark every reference to the CJA 2010, the €15,000 threshold and your reporting-officer arrangements — that is your gap list.
- Update CDD triggers to €10,000 for occasional transactions and add the €3,000 occasional-cash rule.
- Decide and document who will hold the board-level compliance manager and compliance officer roles, including sanctions responsibility.
- Set a cash-acceptance policy that respects the €10,000 cap.
- Refresh your business-wide risk assessment against the AMLR rather than patching the CJA 2010 version.
- Confirm your goAML and ROS registrations and your RBO designated-person access are current — those obligations continue.
- Diarise a full review well before 10 July 2027, and watch AMLA for the technical standards still landing.
Where CompliDesk fits
CompliDesk Ireland is being built AMLR-native — policies, thresholds and workflows keyed to Regulation (EU) 2024/1624 from day one, not retrofitted from the old regime. Start with our AMLR explainer for the full picture of what changes and when.
General information, not legal advice. This article provides general information about EU and Irish anti-money-laundering requirements. It is not legal, tax or compliance advice. Regulatory detail is still evolving through 2026–27 — verify against primary sources (EUR-Lex, AMLA, and your sector’s Irish supervisor) and seek qualified advice before acting.