Frequently asked questions

The AMLR is Regulation (EU) 2024/1624, the EU’s single anti-money-laundering rulebook. It applies directly in Ireland from 10 July 2027 with no Irish transposition needed, replacing the substantive framework of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Football clubs and agents come into scope later, on 10 July 2029.

They are three parts of one EU package. The AMLR (Regulation 2024/1624) sets the rules firms follow; AMLD6 (Directive 2024/1640) reshapes the institutional side — supervisors, FIU powers and beneficial-ownership registers — and is transposed by each member state; and AMLA is the new EU Anti-Money Laundering Authority in Frankfurt, operational since 1 July 2025, which issues the technical standards and guidance filling in the detail.

Both, in effect. Irish law calls regulated firms “designated persons”; the AMLR uses “obliged entities”. If you are a designated person today — an accountant, solicitor, estate or letting agent, TCSP or high-value goods dealer — expect to be an obliged entity under the AMLR from 10 July 2027.

Two named roles: a compliance manager at board (management-body) level, and a compliance officer of sufficiently high standing who runs day-to-day compliance. From 10 July 2027 the compliance officer is also responsible for implementing targeted financial sanctions. Small firms can designate existing senior people, but the appointments must be documented. See our guide on appointing the two roles.

€10,000, down from €15,000 today. Occasional cash transactions of €3,000 or more trigger limited customer due diligence, and crypto-asset service providers apply CDD from €1,000.

The AMLR caps cash payments for commercial transactions at €10,000, counted across single or linked operations, directly applicable EU-wide from 10 July 2027. Splitting a purchase into smaller cash payments does not avoid the cap — linked payments are added together.

No. Ireland has no threshold transaction report (TTR) regime, so there is no report triggered simply by transaction size. Irish reporting is suspicion-based — though a customer trying to structure payments around the cash rules is a classic reason to form a suspicion and file an STR.

The AMLR’s high-net-worth test is cumulative: enhanced due diligence applies where you handle assets of €5 million or more for a client whose total wealth is €50 million or more. AMLA guidance on assessing the €50 million test is due by 10 July 2027.

Anyone with an ownership interest of 25% or more in the client, directly or indirectly, under the AMLR’s harmonised EU-wide test — alongside those who otherwise control the entity. Following a review due by 2029, the Commission may set a lower threshold of 15% or lower for high-risk sectors by delegated act.

Yes, for clients on the register. Since April 2021, Irish designated persons must obtain an extract from the Register of Beneficial Ownership before entering a new business relationship, and must report discrepancies between the register and what they find (Reg 20(3)(b), SI 110/2019). These duties carry across under the new framework.

Your firm registers for designated-person access using the BEN3A1 form, and each extract costs a flat €2.50. Access is tiered following the CJEU’s ruling: competent authorities get full access, designated persons get restricted access. There is no public API, so extracts are obtained through the RBO portal.

No — there are three. The RBO covers companies and industrial and provident societies; CRBOT, run by Revenue, covers trusts; and the Central Bank maintains the register for ICAVs, unit trusts and credit unions. AMLD6 connects national registers EU-wide via BORIS and gives registrars new verification powers.

In two places. An Irish STR is dual-reported: to FIU Ireland (An Garda Síochána) through the goAML portal at fiu-ireland.ie, and to the Revenue Commissioners through ROS as an XML upload. The obligation is only met when both submissions are made.

No. goAML can generate an XML file of the report you submitted, and ROS accepts that goAML-generated XML. You prepare one report, submit it on goAML, then upload the XML to ROS — and record both submission dates and acknowledgements.

Your Money Laundering Reporting Officer (MLRO). The MLRO must be registered on both systems — goAML with FIU Ireland and ROS with Revenue — before a report is ever needed. Sorting both registrations is a one-off setup task worth doing now.

Under the AMLR, requests from the FIU must be answered within five working days, with shorter periods for some categories. Build your record-keeping so client information can actually be produced at that speed — a paper archive in storage will not manage it.

It depends on your sector. The Central Bank supervises banks, funds, payments, insurers and CASPs; the Law Society supervises solicitors; the designated accountancy bodies (Chartered Accountants Ireland, ACCA, CPA Ireland and others) supervise their member firms; the PSRA supervises estate agents, letting agents, auctioneers and property managers; and the AMLCU at the Department of Justice supervises TCSPs, high-value goods dealers and accountants or tax advisers not in a designated body.

An administrative financial sanctions regime for the AMLCU-supervised sectors has been in force since 30 June 2026 (S.I. No. 307 of 2026). Enforcement gained teeth before the AMLR even applies — TCSPs, high-value goods dealers and unaffiliated accountants should treat supervision as carrying real financial consequences today.

Ireland launched its National Risk Assessment and a 30-point AML/CFT Action Plan on 18 June 2026, setting the national agenda through the AMLR’s application date. Alongside AMLA’s technical standards, this is one of the two streams of change worth watching between now and 10 July 2027.

AMLR-native compliance software for Irish designated persons: client onboarding with KYC and KYB verification, a Business-Wide Risk Assessment and policy generator mapped to the AMLR, sanctions and PEP screening, a guided RBO extract workflow, an STR builder with goAML-compatible XML export and dual-submission tracking, plus training logs and a full audit trail. It was built and battle-tested through Australia’s 2026 AML reform with real paying firms.

Free early access is available now for firms that join the waitlist. Indicative launch pricing is €19, €49 or €79 per month plus VAT depending on plan, with unlimited clients on every plan. Additional identity verifications cost €3 each. See the pricing page for what each plan includes.

No. Every plan includes unlimited clients — pricing does not penalise a growing client book. The only usage-based cost is additional identity verifications, at €3 each.

In the EU, on AWS eu-west-1 in Dublin. Client and KYC data stays inside the jurisdiction your clients expect, supporting your own GDPR obligations. See the security and data residency page for detail.

No — and be cautious of any vendor claiming otherwise. CompliDesk prepares the records, exports goAML-compatible XML and tracks submissions and acknowledgements, but your MLRO files STRs on goAML and ROS, and your firm makes its own RBO discrepancy reports. The software’s job is to make each filing prepared, recorded and evidenced.