Definition
The EU cash cap is the limit set by the AMLR on cash payments for commercial transactions: €10,000, whether paid as a single operation or as a series of linked operations. It applies directly in Ireland from 10 July 2027 without national transposition. Separately, occasional cash transactions of €3,000 or more trigger limited customer due diligence.
What it is
Regulation (EU) 2024/1624 (AMLR) introduces an EU-wide cap on cash payments for commercial transactions: €10,000. The cap applies whether the payment is made as a single operation or split across linked operations — structuring a €14,000 sale into two cash instalments does not take it outside the rule. Because the AMLR is a directly applicable regulation, the cap takes effect in Ireland from 10 July 2027 without any Irish transposing legislation.
The cap travels with a related CDD rule: occasional cash transactions of €3,000 or more trigger limited customer due diligence, sitting below the general €10,000 CDD threshold for occasional transactions.
Why it matters for Irish firms
Any Irish business that takes meaningful cash — and any designated person advising or acting for one — needs the cap wired into how transactions are accepted. For high-value goods dealers, including precious metals and stones dealers who remain in AMLR scope, this reshapes day-to-day payment acceptance. For accountants, solicitors and estate agents, cash appearing anywhere near a transaction becomes a structured decision point: is it within the cap, does the linked-operations rule bite, and has the €3,000 limited-CDD trigger been met?
One clarification saves confusion with other regimes: Ireland has no threshold transaction reporting regime. Cash above a given amount is not automatically reportable to FIU Ireland — reporting remains suspicion-based. The cash cap is a prohibition on accepting the payment, not a reporting trigger; though the circumstances around an attempted over-the-cap cash payment may well inform an STR decision on their own merits.
What changes under the AMLR
The cap is itself the change — there is currently no equivalent EU-wide cash limit applying to Irish commercial transactions under the CJA 2010 regime. From 10 July 2027, firms need front-line staff who recognise the €10,000 cap and the linked-operations rule, and workflows that catch the €3,000 occasional-cash CDD trigger before the money is taken.
How CompliDesk helps
CompliDesk Ireland builds cash-rule warnings into client and transaction workflows, flagging the €10,000 cap and the €3,000 CDD trigger as they arise — see the AMLR explainer for the wider 2027 rulebook.
Related terms
General information, not legal advice. This definition provides general information about EU and Irish anti-money-laundering requirements. Regulatory detail is still evolving through 2026–27 — verify against primary sources (EUR-Lex, AMLA, and your sector’s Irish supervisor) and seek qualified advice before acting.