Tax advisers under the AMLR: what changes for your practice

Tax advisers have been designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 for years, so AML is not news to you. What is news is that the rulebook you built your procedures on is being replaced. From 10 July 2027, the EU's AML Regulation (the AMLR, Regulation (EU) 2024/1624) applies directly in Ireland — no transposing Act, no local re-drafting of the core rules. For a tax practice, several of its changes are not cosmetic: thresholds move, a wealth-based enhanced due diligence test arrives that is squarely relevant to tax clients, and compliance roles become prescribed rather than assumed.

Here is what changes for your practice, and what does not.

Who supervises tax advisers — and does that change?

If you are a member of a designated accountancy body — Chartered Accountants Ireland, ACCA, CPA Ireland and others — that body supervises your AML compliance. If you provide tax services without such membership, your supervisor is the AMLCU in the Department of Justice — and note that the AMLCU's administrative financial sanctions regime is in force, since 30 June 2026 under S.I. No. 307 of 2026. The AMLR does not change who supervises you on day one; it changes the rules they supervise against. Irish law calls you a "designated person"; the AMLR says "obliged entity". Use both in your documents through the transition.

Which thresholds move, and where do they bite in tax work?

Three numbers change or arrive:

• €10,000 — the CDD threshold for occasional transactions, down from €15,000, counting linked operations together.
• €3,000 — occasional cash transactions at or above this figure trigger limited CDD.
• €10,000 — an EU-wide cap on cash payments in commercial transactions, single or linked.

Most tax engagements are business relationships rather than occasional transactions, so the deeper point is hygiene: any procedure, checklist or training slide in your practice that says €15,000 is wrong from 10 July 2027. The cash cap matters for advice too — clients in cash-heavy trades will ask what it means for them, and "I had not heard of it" is not an answer a tax adviser wants to give.

Does the high-net-worth EDD test catch your clients?

This is the AMLR change most directly aimed at practices like yours. Enhanced due diligence is required for high-net-worth relationships where a cumulative test is met: you handle assets of €5m or more for a client whose total wealth is €50m or more. Both limbs must be satisfied — a client with €50m of total wealth for whom you handle a modest engagement does not trigger it, and nor does handling €5m for a client of ordinary wealth.

For most small practices this catches nobody. But tax advisers are exactly the professionals who occasionally act for a genuinely wealthy family, an exiting founder, or a landed estate. Build a screening question into onboarding — an informed estimate of total wealth and of the assets you will handle — so the test is applied deliberately. AMLA guidance on applying the €50m total-wealth limb is due by 10 July 2027; where the final detail depends on that guidance, say so in your procedures and update when it lands, rather than inventing your own specifics.

What do the prescribed compliance roles mean in a small practice?

The AMLR requires a compliance manager at board level and a compliance officer of sufficiently high standing — and from 10 July 2027 the compliance officer also carries responsibility for implementing targeted financial sanctions. In a two-partner practice this is less about hiring and more about formalising: decide who holds each role, record the designation, and make sure the sanctions responsibility is understood as part of the job rather than a surprise inside it. The informal "our senior partner is sort of the MLRO" arrangement that survived under the CJA 2010 needs to become a documented structure.

What stays Irish?

The reporting and register plumbing does not change. Suspicious Transaction Reports remain dual-reported: to FIU Ireland via the goAML portal and to the Revenue Commissioners via ROS — guidance on the Revenue side is at revenue.ie. Ireland has no threshold transaction reporting regime, and the AMLR does not create one. Your RBO duties continue: obtain an extract from the Register of Beneficial Ownership before a new business relationship with a corporate client, and report discrepancies. Two AMLR record rules deserve system attention: FIU information requests must be answered within 5 working days (shorter for some categories), which is only achievable if client records are retrievable quickly; and records must be retained for 5 years and then deleted, which means your practice needs a deletion routine as well as an archive.

What to do now

1. Search your procedures, letters of engagement and training materials for "€15,000" and every CJA 2010 reference — that is your first gap list.
2. Add a high-net-worth screening question to onboarding so the cumulative €5m/€50m test is applied on evidence.
3. Designate the compliance manager and compliance officer, record it, and brief the officer on sanctions responsibility.
4. Test how fast you could assemble a client file — the 5-working-day FIU clock assumes you can.
5. Refresh your business-wide risk assessment against the AMLR rather than patching the old one.
6. Confirm goAML, ROS and RBO access are all current.

Where CompliDesk fits

CompliDesk Ireland bakes the AMLR's thresholds, the high-net-worth test and the role designations into your client workflows, so the 2027 changes arrive as settings rather than rewrites. Start with our AMLR explainer for the full picture.