Unaffiliated accountants and tax advisers: the AMLCU is your supervisor

If you provide accountancy or tax advisory services in Ireland but you are not a member of a designated accountancy body, a common assumption can trip you up: that because the accountancy bodies do not regulate you, nobody is checking your AML compliance.

Wrong. You are still a "designated person" under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. The difference is who supervises you. For unaffiliated accountants and tax advisers, that supervisor is the Anti-Money Laundering Compliance Unit — the AMLCU — within the Department of Justice.

And the ground is about to shift again. From 10 July 2027, Regulation (EU) 2024/1624 (AMLR) — the EU's directly applicable single rulebook — replaces the substantive AML rules you currently work under. This post explains what AMLCU supervision means in practice, and what your firm should be doing between now and that date.

Who counts as "unaffiliated"

Ireland splits AML supervision of the accountancy profession by membership, not by the work you do:

The obligations come from the same statute either way. Membership changes your supervisor, not the substance of your duties. Client due diligence, a business-wide risk assessment, internal policies and procedures, suspicious transaction reporting, record-keeping: all of it applies to you exactly as it applies to a body-regulated practice.

If you are unsure which side of the line you sit on — say you let a membership lapse — resolve it now. Registering with the wrong supervisor, or with none, is a foundational compliance gap. The AMLCU publishes guidance for its supervised sectors at amlcompliance.ie.

What AMLCU supervision looks like

The AMLCU is the competent authority for several sectors that fall outside the professional bodies and the Central Bank of Ireland: trust or company service providers, high-value goods dealers, and unaffiliated accountants and tax advisers among them. In practice, being an AMLCU-supervised firm means:

• You should be registered with the AMLCU as a designated person in its supervised population.
• You can be inspected. Expect a compliance check to ask for your risk assessment, policies, CDD files and training records — not a verbal assurance that you "know your clients."
• You are expected to keep up with AMLCU guidance and sector risk communications.

One development worth taking seriously: an administrative financial sanctions regime covering the AMLCU-supervised sectors has been in force since 30 June 2026 (S.I. No. 307 of 2026) — sharper enforcement tools before the AMLR even applies. Ireland has also published an AML/CFT Action Plan for 2026–2027. Supervision of the non-financial sectors is tightening, not relaxing.

What stays the same until July 2027

Between now and 10 July 2027, the CJA 2010 remains your rulebook. That means your firm should already have, and be able to evidence:

• A documented business-wide risk assessment covering your clients, services, delivery channels and geographic exposure.
• Written AML policies, controls and procedures proportionate to your practice.
• Client due diligence on every client, with beneficial ownership identified for corporate clients — including obtaining an RBO extract from rbo.gov.ie before entering a new business relationship, and reporting discrepancies between the register and what you find.
• Registration for suspicious transaction reporting. STRs in Ireland 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 before you ever need to file.
• Training records showing staff know how to recognise and escalate suspicion.

If anything on that list is missing, fix it under the current regime first. An inspection will assess you against today's law, and every element carries forward into the AMLR world anyway.

What the AMLR changes from 10 July 2027

The AMLR — Regulation (EU) 2024/1624 — applies directly in Ireland with no transposition. It calls regulated firms "obliged entities" rather than "designated persons," and it rewrites the detail of your obligations. Alongside it, Directive (EU) 2024/1640 (AMLD6) restructures the supervisory layer, and the new EU Anti-Money Laundering Authority (AMLA) in Frankfurt drives convergence in how national supervisors — including yours — enforce the rules.

For a small accountancy or tax practice, the headline changes are:

• Lower CDD thresholds. Occasional transactions trigger CDD at 10,000 euro (down from 15,000 euro), and occasional cash transactions of 3,000 euro or more trigger limited CDD.
• An EU-wide cash cap. Commercial transactions are capped at 10,000 euro in cash, whether as a single payment or linked operations. If clients pay you — or each other, in deals you facilitate — in cash, this matters.
• Harmonised beneficial ownership. The beneficial-owner test is 25 per cent or more ownership interest, direct or indirect, applied uniformly across the EU.
• Prescribed compliance roles. Obliged entities must designate a board-level compliance manager and a compliance officer of sufficiently high standing. In a small practice these roles may sit with the same people who do everything else — but they must be formally designated, and the compliance officer also takes responsibility for targeted financial sanctions implementation from 10 July 2027.
• Enhanced due diligence for high-net-worth relationships, where a client holds assets of 5 million euro or more handled for a client whose total wealth is 50 million euro or more.
• Tighter reporting and retention discipline. FIU requests must be answered within 5 working days (shorter for some categories), and records must be retained for 5 years and then deleted.

The practical consequence: policies and risk assessments written for the CJA 2010 will be out of date on 10 July 2027. They will cite the wrong instrument, the wrong thresholds and the wrong role structure. For a fuller walkthrough of the package, see the AMLR explainer.

What to do now

1. Confirm your supervisory position. If you are not a member of a designated accountancy body, verify you are registered with the AMLCU and that your details are current.
2. Register your MLRO on goAML with FIU Ireland and on ROS with Revenue, if not already done. Do this before you need to file, not the week you need to file.
3. Set up designated-person access to the RBO so beneficial-ownership checks on new corporate clients are routine, not scramble.
4. Review your business-wide risk assessment against your current client base — and diarise a full AMLR-alignment refresh for early 2027.
5. Map your current policies against the AMLR's headline changes: the 10,000 euro CDD threshold, the 3,000 euro occasional-cash trigger, the cash cap, the compliance manager and compliance officer roles, and 5-year retention with deletion.
6. Decide who will hold the prescribed compliance roles, and record that decision.
7. Refresh staff training and keep the log — it is one of the first things an inspector asks for.

Getting AMLR-ready without the spreadsheet sprawl

CompliDesk Ireland is being built AMLR-native for the firms the big vendors overlook — including AMLCU-supervised practices. If you want a structured starting point, download the AMLR readiness checklist or check your position with our scope quiz.