Enhanced due diligence for high-net-worth clients: who the €5m and €50m tests 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 change you need to plan for. From 10 July 2027, Regulation (EU) 2024/1624 (the AMLR) applies directly in Ireland, and it introduces enhanced due diligence for high-net-worth business relationships. Two figures matter — and, crucially, they work together: the test is met where assets of €5 million or more are handled within the relationship for a client whose total wealth is €50 million or more. Both limbs must be satisfied.

Most Irish designated persons have run enhanced due diligence for years under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 — typically for politically exposed persons and higher-risk situations flagged by their own risk assessment. What changes under the AMLR is that significant client wealth itself becomes a trigger you must recognise and respond to. That is a different way of thinking, and it needs preparation before the date, not after.

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 CJA 2010, and because it is a regulation rather than a directive, it applies without Irish transposition. The same text binds a solicitor in Cork and a notary in Kraków.

Part of the harmonisation project is tightening the situations where enhanced due diligence is mandatory rather than discretionary. High-net-worth relationships are one of those situations. The logic is straightforward: large pools of private wealth 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 two tests, in plain English

The AMLR sets out two thresholds for identifying a high-net-worth relationship:

• Limb one — assets of €5 million or more. The scale of assets actually handled within the relationship with your firm.
• Limb two — total wealth of €50 million or more. The client's overall wealth, 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 — that brings the enhanced measures in.

The second test is the harder one to operate, because assessing a client's total wealth is not something most Irish practices 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.

One important framing point: these thresholds do not make wealthy clients unwelcome or suspicious. They make them a category where your firm must apply deeper checks and better documentation. A well-run file on a high-net-worth client is entirely routine — it just has more in it.

Who gets caught in practice

Here are three deliberately hypothetical examples of the kind of client an Irish firm might need to reassess. None of these describe real people or real matters.

• The business exit. A hypothetical client sells their engineering company for €8 million and engages your accountancy practice for post-sale tax and structuring work. The assets handled comfortably exceed €5 million — so the question becomes limb two: does this client's total wealth reach €50 million? If it does, the enhanced measures apply.
• The land sale. A hypothetical farming family instructs a solicitor on the sale of land and associated holdings worth roughly €6 million. Limb one is in view — and whether the enhanced measures apply then turns on the family's total wealth reaching €50 million.
• The quiet portfolio. A hypothetical client asks an estate agent to sell a single €900,000 house — modest in itself. Even if the client's overall wealth approaches €50 million, this specific enhanced measure is not triggered, because the assets handled fall short of the €5 million limb. But the example still matters: wealth signals like this belong in your general risk-rating, and a later, larger instruction from the same client could bring both limbs together.

The lesson from the third example is the uncomfortable one: the wealth limb is invisible from a single instruction. Your onboarding process needs a structured way to ask about total wealth whenever the assets handled are substantial — not just to react to obvious wealth.

What enhanced due diligence actually means for your 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 wealth thresholds are nowhere in it, 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, ACCA, CPA Ireland) 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 the high-net-worth provisions.

What to do now

1. Scan your client book. Identify existing relationships where both limbs could plausibly be met — assets of €5 million or more handled for clients whose total wealth could approach €50 million. A rough first pass is fine — the point is knowing the size of the problem.
2. 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.
3. Refresh your EDD procedure. Write the high-net-worth trigger into your AML policies and your Business-Wide Risk Assessment, alongside your existing triggers.
4. Decide who signs off. Assign senior responsibility for approving high-net-worth relationships, and record it.
5. 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.
6. Train the front line. The people who open files need to recognise the trigger. A short briefing now beats a remediation exercise later.

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.