Jewellers and precious metals dealers: your place in the AMLR

If your firm buys or sells jewellery, gold, silver, precious stones or other high-value goods in Ireland, you have probably been living with anti-money laundering obligations for years. Under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, high-value goods dealers who accept large cash payments are "designated persons", supervised by the Anti-Money Laundering Compliance Unit (AMLCU) at the Department of Justice.

That world is about to change. From 10 July 2027, Regulation (EU) 2024/1624 (AMLR) applies directly in Ireland, with no need for national transposition. It replaces the substantive AML rulebook your firm currently works under, and it names traders in high-value and luxury goods — including precious metals and stones dealers — as "obliged entities" in their own right. If your compliance programme is a Word document written for the 2010 Act, it will be out of date on day one.

Here is what the shift means in practice, and what to do about it while there is still runway.

Where you stand today

Under the CJA 2010, as amended, your firm is a designated person and the AMLCU is your competent authority for AML supervision. That means you are already expected to have a risk assessment, customer due diligence (CDD) procedures, staff training and a process for reporting suspicions.

Two things are worth flagging about the current regime:

• Suspicious Transaction Reports (STRs) in Ireland are dual-reported: to FIU Ireland via the goAML portal and to the Revenue Commissioners via ROS. Both registrations sit with your MLRO.
• Ireland has no threshold transaction reporting regime. There is no routine report just because a sale crosses a euro figure. Reporting is driven by suspicion, not thresholds — and that remains the case under the AMLR.

An administrative financial sanctions regime for sectors the AMLCU supervises has been in force since 30 June 2026 (S.I. No. 307 of 2026). In plain terms: enforcement is getting teeth before the AMLR even arrives. Firms with thin files should treat that as the real deadline.

The AMLR keeps you in scope — and tightens the thresholds

The AMLR's single rulebook applies EU-wide from 10 July 2027. For high-value dealers, three threshold changes matter most.

Take each in turn.

The 10,000 euro CDD threshold

Where you do not have an ongoing business relationship with a customer, full CDD is triggered for occasional transactions of 10,000 euro or more. The old 15,000 euro figure disappears. For a jeweller, that catches a meaningful slice of engagement rings, watches, bullion and trade purchases that previously sat under the line.

The 3,000 euro cash trigger

Occasional cash transactions of 3,000 euro or more trigger limited CDD. This is a genuinely low bar for a cash-friendly trade. If a walk-in customer pays 3,500 euro in notes for a bracelet, you need to identify them — even though the sale is well below the full CDD threshold.

The 10,000 euro cash cap

Separately from CDD, the AMLR imposes a directly applicable EU-wide cap of 10,000 euro on cash payments for commercial transactions. The cap applies to single payments and to linked operations — so splitting one 14,000 euro sale into two cash payments of 7,000 euro does not take it outside the rule.

A clearly hypothetical example: a customer wants to buy a 12,000 euro watch and offers cash. From 10 July 2027, your firm cannot lawfully accept the full amount in cash. The customer pays by transfer or card instead — and because the transaction is 10,000 euro or more, full CDD applies before you complete it. Your till procedures, your staff training and your point-of-sale scripts all need to reflect this.

Selling to companies: beneficial ownership and the RBO

If you deal with corporate customers — trade buyers, corporate gifting, bullion purchases through a company — the AMLR harmonises the beneficial ownership test at 25 per cent or more ownership interest, direct or indirect, across the EU.

In Ireland that connects to an existing duty many high-value dealers overlook. Since April 2021, designated persons must obtain an extract from the Register of Beneficial Ownership before entering a new business relationship with a company, and must report discrepancies between the register and what the customer tells you. Access for designated persons runs through the BEN3A1 form, with a small per-extract fee. There is no API — it is a manual check your file needs to evidence.

Your programme needs more than a threshold update

The AMLR is not only about numbers at the counter. It also prescribes how your compliance function is organised:

• A compliance manager at board or equivalent senior level, plus a compliance officer of sufficiently high standing. In a small firm these responsibilities still need to be formally assigned and documented.
• From 10 July 2027 the compliance officer also becomes responsible for implementing targeted financial sanctions — screening is no longer an optional extra.
• Requests from the FIU must be answered within 5 working days, and shorter for some categories. You need records you can actually retrieve at that speed.
• Records must be retained for 5 years and then deleted. Keeping everything forever is itself a compliance failure under the new regime, so retention and deletion need a process.

Your business-wide risk assessment, policies and procedures should all be rebuilt against the AMLR's articles rather than patched from CJA 2010 templates.

What to do now

1. Confirm your scope position. If you accept or could accept large cash payments for high-value goods, work on the basis that you are in scope now under the CJA 2010 and will be an obliged entity under the AMLR.
2. Check your registrations: goAML with FIU Ireland, ROS with Revenue for STR dual reporting, and RBO designated-person access via BEN3A1.
3. Decide your cash policy early. Many dealers will choose an internal cash limit below 10,000 euro with a hard stop, plus a 3,000 euro identification procedure. Write it down and train the counter staff.
4. Map your current policies and risk assessment against the AMLR and list the gaps — thresholds, sanctions screening, compliance roles, retention.
5. Assign the compliance manager and compliance officer roles formally, in writing.
6. Diarise a full programme refresh well before 10 July 2027, and re-check supervisor guidance from the AMLCU as it lands.

How CompliDesk can help

CompliDesk Ireland is being built AMLR-native for exactly this transition — cash-rule warnings at the 10,000 euro cap and 3,000 euro trigger, an AMLR policy pack and business-wide risk assessment generator, and an RBO workflow with evidence storage. See whether your firm is caught with our am I in scope check.