The EU AMLR explained for Irish firms: what actually changes on 10 July 2027

If your firm is a designated person under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, you already run an AML programme. So it is tempting to file the EU's new AML package under "more of the same" and move on.

That would be a mistake. From 10 July 2027, Regulation (EU) 2024/1624 — the AMLR — becomes the substantive AML rulebook for Irish firms. It is a directly applicable EU regulation, not a directive. It does not wait for the Oireachtas to transpose it. On that date, the detailed rules you follow on customer due diligence, beneficial ownership, internal controls and reporting come from the AMLR itself. Here is what that means in practice.

Three instruments, not one

The EU AML package is three separate instruments. People conflate them constantly, so it is worth keeping them straight.

For a small or medium Irish firm, the AMLR is the one that changes your daily work. AMLD6 shapes the supervisory landscape around you. AMLA sets the technical standards and guidance everyone will follow — you can track its output at amla.europa.eu.

"Designated person" becomes "obliged entity"

Irish law calls regulated firms designated persons. The AMLR calls them obliged entities. The terminology shift matters less than what sits behind it: instead of Irish rules built on EU directives, you will apply one EU-wide rulebook directly. Your existing CJA 2010-era policies, procedures and risk assessment were written for the old framework. On 10 July 2027 they will be measuring your firm against a rulebook that no longer applies.

That is the core problem to plan for. Not "become compliant" — you already are, under the current regime — but "become AMLR-ready".

The headline changes to your CDD

The most concrete shifts are in customer due diligence thresholds:

• Occasional transactions: the CDD threshold drops to 10,000 euro, from 15,000 euro today.
• Occasional cash transactions of 3,000 euro or more trigger limited CDD.
• Crypto-asset service providers (CASPs): CDD applies from 1,000 euro.
• Enhanced due diligence for high-net-worth relationships: clients with assets of 5 million euro or more handled for a client whose total wealth is 50 million euro or more, attract EDD. AMLA guidance on the 50 million euro test is due by 10 July 2027.

If your client onboarding checklist has 15,000 euro hard-coded into it — and most CJA 2010-era checklists do — it will be wrong on day one.

A directly applicable cash cap of 10,000 euro

The AMLR introduces an EU-wide cap of 10,000 euro on cash payments for commercial transactions, covering single and linked operations. The cap applies in Ireland without any Irish implementing act.

One clarification, because firms sometimes assume otherwise: Ireland has no threshold transaction reporting regime. There is no obligation to report cash transactions above a set amount to any authority simply because of their size. The cash cap is a limit on accepting large cash payments, not a reporting trigger. Your reporting obligation remains the Suspicious Transaction Report, dual-reported to FIU Ireland via the goAML portal (fiu-ireland.ie) and to the Revenue Commissioners via ROS.

Beneficial ownership: harmonised at 25%

The AMLR harmonises the beneficial-owner definition EU-wide at 25% or more ownership interest, direct or indirect. The Commission may later set a lower threshold — to 15% or lower — for high-risk sectors by delegated act, following a review due by 2029.

Your existing RBO duties continue in the meantime. Since April 2021, designated persons must obtain an RBO extract before entering a new business relationship and must report discrepancies between the register (rbo.gov.ie) and what their own due diligence finds. AMLD6 goes further, connecting beneficial-ownership registers across the EU and giving registrars new verification powers. Expect discrepancy reporting to be taken more seriously, not less.

Prescribed compliance roles — and a sanctions job

The AMLR prescribes two roles: a board-level compliance manager and a compliance officer of sufficiently high standing. These are formally designated roles, and from 10 July 2027 the compliance officer also becomes responsible for implementing targeted financial sanctions.

Two other operational points to note. FIU requests must be answered within 5 working days (shorter for some categories) — check whether your file retrieval could actually meet that. And records must be retained for 5 years, then deleted — retention and deletion, not retention alone.

Your supervisor does not change — but the climate does

The AMLR does not move you to a new regulator. Estate agents, letting agents and auctioneers remain supervised by the PSRA. Solicitors remain with the Law Society of Ireland. Accountants who are members of a designated accountancy body remain with that body — Chartered Accountants Ireland, ACCA or CPA Ireland. TCSPs, high-value goods dealers and unaffiliated accountants remain with the AMLCU in the Department of Justice. Financial firms remain with the Central Bank of Ireland.

What changes is the environment. AMLA in Frankfurt drives convergence in how national supervisors work, and Ireland has published an AML/CFT Action Plan for 2026 to 2027. An administrative financial sanctions regime for the AMLCU's sectors has been in force since 30 June 2026 (S.I. No. 307 of 2026) — before the AMLR even applies. Supervision is tightening on both fronts.

What to do now

You have time, but the useful preparation is front-loaded. A sensible sequence:

1. Run a gap analysis of your current policies, controls and procedures against the AMLR — not against the CJA 2010, which is the rulebook being replaced.
2. Refresh your Business-Wide Risk Assessment with the new thresholds and scope in mind.
3. Find every hard-coded threshold in your onboarding forms and checklists — 15,000 euro occasional-transaction figures in particular — and plan the switch to 10,000 euro and the 3,000 euro cash trigger.
4. Designate the compliance roles: decide who will be your board-level compliance manager and who your compliance officer, and document it.
5. Check your registrations: goAML with FIU Ireland, Revenue ROS for STR dual reporting, and RBO designated-person access.
6. Review record-keeping so you can both retain for 5 years and delete afterwards, and respond to an FIU request within 5 working days.
7. Watch AMLA's technical standards as they land through 2026 and 2027.

Getting AMLR-ready with CompliDesk

CompliDesk Ireland is being built for the AMLR from day one — policy packs, risk assessments and CDD workflows mapped to Regulation (EU) 2024/1624 rather than retrofitted from the old regime. Start with our free AMLR readiness checklist to see where your firm stands today.