Enhanced due diligence for high-net-worth clients: who the €5m and €50m tests actually catch

If your firm acts for wealthy clients — a retiring business owner, a family selling land, an investor with a property portfolio — the EU's new AML rulebook has a provision you have probably heard about, and quite possibly heard about wrongly. From 10 July 2027, Regulation (EU) 2024/1624 (the AMLR) applies directly in Ireland, and Article 34(4) introduces prescribed enhanced due diligence for high-net-worth business relationships. Two figures matter — and, crucially, they work together: the test is met where a higher-risk relationship involves the handling of assets of €5 million or more through personalised services for a client whose total assets are €50 million or more (excluding the client's private residence). Both limbs must be satisfied.

Here is the part that is widely misreported: this duty does not fall on every Irish designated person. Article 34(4) imposes it on credit institutions, financial institutions and trust or company service providers (TCSPs). A solicitors' practice, an accountancy firm or an estate agency is not directly bound by it — unless the firm also provides TCSP services such as company formation, registered office, trustee or nominee work, which many Irish professional practices do. Knowing which side of that line your firm sits on is the first planning step.

Why this exists at all

The AMLR is the EU's "single rulebook". It replaces the substantive AML rules Irish firms currently follow under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, and because it is a regulation rather than a directive, it applies without Irish transposition. The same text binds a bank in Cork and a TCSP in Kraków.

Part of the harmonisation project is tightening the situations where enhanced due diligence is mandatory rather than discretionary. High-net-worth relationships at wealth-handling institutions are one of those situations. The logic is straightforward: large pools of private wealth managed through personalised services can be attractive channels for laundering, and the EU wants a consistent, elevated standard of scrutiny applied to them across all member states — not a patchwork of national judgment calls.

The test, in plain English

Four conditions come together before Article 34(4) bites:

• You are in the addressee group — a credit institution, financial institution or TCSP.
• The relationship is identified as higher risk — the test operates inside your risk-rating, not instead of it.
• Limb one — assets of €5 million or more are handled within the relationship, through personalised services.
• Limb two — total assets of €50 million or more. The client's overall wealth (financial, investable and real-estate assets, excluding their private residence), not just what passes through your engagement.

The two limbs are cumulative: a €6 million transaction for a client of ordinary wealth does not trigger this measure, and nor does a modest engagement for a very wealthy client. It is the combination — substantial assets handled for a client of substantial total wealth, in a higher-risk relationship — that brings the enhanced measures in.

The wealth limb is the harder one to operate, because assessing a client's total assets is not something most firms have ever had to do in a structured way. The EU knows this: AMLA — the new Anti-Money Laundering Authority in Frankfurt — is due to issue guidance on the €50 million test by 10 July 2027. Until that guidance lands, treat the detail of how total wealth is measured as unsettled, and build your processes so they can absorb the final position rather than hard-coding assumptions now. You can track AMLA's output directly at amla.europa.eu.

What if your firm is NOT a bank, financial institution or TCSP?

Then Article 34(4) is not your obligation — but it would be a mistake to file it under "irrelevant", for three reasons:

• Many professional practices are TCSPs without using the label. If your accountancy or law firm forms companies, provides registered offices, or acts as or arranges directors, trustees or nominees, that part of your business is TCSP activity — and the high-net-worth test can reach it.
• Wealth remains a risk factor for everyone. Enhanced due diligence under the general risk-based rules still applies wherever your own risk assessment identifies higher risk — and substantial client wealth, complex structures and large transactions are classic inputs to that rating. The AMLR does not make wealthy clients automatically high-risk for your firm; it also does not make them exempt from your judgment.
• Your clients' banks will ask. From July 2027, the institutions holding and moving your clients' money must run this test. Files that already evidence source of funds and source of wealth make those interactions faster for everyone.

What enhanced due diligence actually means for the file

Enhanced due diligence is not a different product — it is standard customer due diligence done to a deeper level and documented more thoroughly. In practice, firms applying EDD generally focus on:

• Source of funds and source of wealth. Where did the money for this transaction come from, and how was the client's overall wealth built? Evidence, not assertion.
• Closer scrutiny of the relationship. More detail on the purpose of the engagement and whether it makes commercial sense for this client.
• Senior sign-off and ongoing monitoring. Higher-risk relationships typically warrant approval at a senior level and more frequent review.

Whatever your current EDD procedure says, check whether it was written for a world where PEP status was the main trigger. If your firm is in the Article 34(4) addressee group — including through TCSP services — and wealth thresholds are nowhere in your procedures, that is a gap to close before July 2027.

Your supervisor will expect to see this

Enforcement in Ireland stays sector-based under Directive (EU) 2024/1640 (AMLD6), which handles the institutional side of the reform. That means the body checking your EDD approach is the one you already know: the PSRA for estate and letting agents, the Law Society of Ireland for solicitors, the designated accountancy bodies (Chartered Accountants Ireland — incorporating CPA Ireland since 2024 — and ACCA, among others) for their members, the AMLCU in the Department of Justice for TCSPs and unaffiliated practitioners, and the Central Bank of Ireland for financial firms. When your supervisor inspects a file after 10 July 2027, they will be inspecting it against the AMLR — including, for firms in scope, the high-net-worth provisions.

What to do now

1. Work out whether Article 34(4) binds you. Financial firm or TCSP — including TCSP services inside a professional practice — means yes. Pure legal, accountancy or property work means no, but wealth stays in your risk-rating.
2. If in scope, scan your client book. Identify relationships where both limbs could plausibly be met. A rough first pass is fine — the point is knowing the size of the problem.
3. If in scope, add wealth-threshold questions to onboarding. Build a structured prompt into new-client intake so the €5m/€50m question gets asked once, consistently, rather than left to individual judgment.
4. Refresh your EDD procedure either way. Write your actual triggers — statutory or risk-based — into your AML policies and your Business-Wide Risk Assessment.
5. Decide who signs off. Assign senior responsibility for approving higher-risk relationships, and record it.
6. Watch for the AMLA guidance. The €50 million test will be shaped by guidance due by 10 July 2027. Diarise a review of your procedure for when it publishes.

Getting AMLR-ready with CompliDesk

CompliDesk Ireland is being built for the AMLR from day one, with EDD triggers, policy templates and a Business-Wide Risk Assessment generator designed around the new rulebook rather than retrofitted from the old one. If you want a head start on your firm's gap analysis, start with the AMLR explainer.