Cash rules at the counter: what high-value goods dealers face from 10 July 2027

If your business sells jewellery, precious metals or stones, art, vehicles, or other high-value goods in Ireland, the way you handle cash at the counter is about to change. From 10 July 2027, Regulation (EU) 2024/1624 (AMLR) applies directly in Ireland. It replaces the substantive anti-money-laundering rulebook your firm has worked under for years — the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 — with a single EU-wide set of rules.

For high-value dealers, the headline changes are about cash: an EU-wide cap of 10,000 euro on cash payments for commercial transactions, and a customer due diligence (CDD) trigger at just 3,000 euro for occasional cash transactions. If your current AML procedures were written around the old thresholds, they will be out of date on day one.

Here is what your firm needs to know, in plain English.

Who supervises you today — and why that matters

Under the CJA 2010, high-value goods dealers are "designated persons," and your AML supervisor is the Anti-Money Laundering Compliance Unit (AMLCU) at the Department of Justice — see amlcompliance.ie. The AMLCU is the body that can inspect your firm and ask to see your risk assessment, your CDD records and your training log.

The AMLR does not change who supervises you, but it changes what they will be checking against. The terminology shifts too: Irish law calls you a "designated person"; the AMLR calls you an "obliged entity." Same firm, new rulebook.

One more reason not to wait: an administrative financial sanctions regime for the AMLCU-supervised sectors has been in force since 30 June 2026 (S.I. No. 307 of 2026), and Ireland has published an AML/CFT Action Plan for 2026–2027. Enforcement is tightening ahead of the new rules, not after them.

The 10,000 euro cash cap

The AMLR introduces a directly applicable, EU-wide cap of 10,000 euro on cash payments for commercial transactions. That covers a single payment — and it also covers linked operations, so a purchase split into several smaller cash payments to stay under the limit is still caught.

For a dealer, the practical consequence is simple: from 10 July 2027, you cannot accept 10,000 euro or more in cash for a sale, however the customer proposes to structure it. Your point-of-sale process, your staff briefing and your written procedures all need to reflect that.

A clearly hypothetical example: a customer wants to buy a 14,000 euro watch and offers 9,000 euro in cash today and 5,000 euro in cash next week. Those are linked operations for the same transaction. Under the AMLR cash cap, that arrangement is not permitted — the cash element of the transaction breaches the cap.

The 3,000 euro cash CDD trigger

Below the cap, cash still carries obligations. Under the AMLR, occasional cash transactions of 3,000 euro or more trigger limited customer due diligence. In practice, that means a walk-in customer paying 3,000 euro or more in cash cannot simply remain anonymous — you need to identify them and keep a record.

Separately, the general CDD threshold for occasional transactions (regardless of payment method) drops to 10,000 euro under the AMLR, down from the 15,000 euro figure firms have been used to. So:

If your staff currently only think about AML checks on very large sales, the 3,000 euro cash trigger is the change most likely to catch your firm out day to day.

Ireland has no threshold transaction report — do not confuse the cap with reporting

A point worth being precise about: Ireland has no regime requiring you to routinely report cash transactions above a threshold to the authorities. The 10,000 euro figure is a cap on accepting cash, not a reporting threshold.

What you do have is the suspicious transaction report (STR) obligation. In Ireland STRs are dual-reported: to FIU Ireland via the goAML portal (fiu-ireland.ie) and to the Revenue Commissioners via ROS (revenue.ie). Your MLRO needs to be registered on both. A customer insisting on structuring payments to avoid the cash rules is exactly the kind of behaviour that should prompt your firm to consider an STR.

Beyond cash: the rest of the AMLR still applies to you

The cash rules are the headline, but they sit inside a wider rulebook that also applies to your firm from 10 July 2027:

• Beneficial ownership. Where your customer is a company, the AMLR harmonises the beneficial-owner test at 25 per cent or more ownership, direct or indirect. As a designated person you must already obtain an extract from the Register of Beneficial Ownership (rbo.gov.ie) before entering a new business relationship, and report discrepancies between the register and what you find.
• Prescribed compliance roles. The AMLR requires a board-level compliance manager plus a compliance officer of sufficiently high standing. In a small dealership these duties will land on the owner or a senior manager — but they need to be formally designated and documented, and the compliance officer also becomes responsible for targeted financial sanctions implementation from 10 July 2027.
• FIU deadlines. Requests from the FIU must be answered within 5 working days — shorter for some categories — so your records need to be retrievable, not buried in a filing cabinet.
• Record keeping. Records must be retained for 5 years and then deleted. Keeping everything forever is no longer the safe option; deletion is part of the obligation.
• Scope. Traders in high-value and luxury goods above thresholds are within the AMLR's scope, and precious metals and stones dealers remain in scope. If you are unsure where your business falls, check before assuming you are out.

What to do now

1. Confirm your firm's position: are you a high-value goods dealer within scope, and is the AMLCU your supervisor? Try our in-scope check if you are unsure.
2. Pull out your current AML policies and mark every threshold. Anything built on 15,000 euro, or silent on a cash cap, needs rewriting for the AMLR figures.
3. Draft a counter procedure for the two cash triggers: limited CDD at 3,000 euro cash, and a hard stop before 10,000 euro cash — including how staff spot linked payments.
4. Refresh your business-wide risk assessment to reflect cash risk in your sector and the new EU rules.
5. Formally designate your compliance manager and compliance officer, and record the appointments.
6. Check your MLRO is registered on goAML and ROS for STR dual reporting.
7. Plan staff training for 2026–27 so everyone at the counter knows the new numbers before 10 July 2027 — and log it, because your supervisor can ask for evidence.

Getting AMLR-ready with CompliDesk

CompliDesk Ireland is built for the AMLR from day one, with cash-rule warnings, CDD workflows and policy templates designed around the new thresholds rather than retrofitted from the old regime. Start with our free AMLR readiness checklist to see where your firm stands.