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CJA 2010 (Criminal Justice Act 2010)

Definition

The CJA 2010 — the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended in 2018 and 2021 — is Ireland’s primary anti-money-laundering law. It defines “designated persons”, sets their customer due diligence, reporting and record-keeping duties, and assigns sector supervisors such as the Central Bank, Law Society, PSRA and AMLCU.

What is the CJA 2010?

The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended — most significantly in 2018 and 2021 to transpose the fourth and fifth EU AML directives — is the statute Irish firms currently live under. It defines the money-laundering offences, sets out who is a designated person, and imposes the familiar obligations: customer due diligence, ongoing monitoring, suspicious transaction reporting, training and record-keeping.

Who supervises designated persons under the CJA 2010?

Supervision is split by sector. The Central Bank of Ireland supervises banks, funds, payment firms, insurers and CASPs; the Law Society supervises solicitors; the designated accountancy bodies (Chartered Accountants Ireland, ACCA, CPA Ireland and others) supervise their members; the PSRA supervises estate agents, letting agents, auctioneers and property management firms; and the AMLCU in the Department of Justice supervises TCSPs, high-value goods dealers and unaffiliated accountants and tax advisers. Enforcement has recently gained teeth: an administrative financial sanctions regime for the AMLCU-supervised sectors has been in force since 30 June 2026 (S.I. No. 307 of 2026).

How does reporting work under the CJA 2010?

Ireland dual-reports suspicious transactions: every STR goes to FIU Ireland (An Garda Síochána) through the goAML portal and to the Revenue Commissioners through ROS, which accepts the goAML-generated XML. Firms must register on both systems. Notably, Ireland has no threshold transaction report (TTR) regime — reporting is suspicion-based, not amount-based.

What changes when the AMLR arrives?

The CJA 2010 does not disappear on 10 July 2027, but the directly applicable AMLR takes over the core rulebook — CDD thresholds, beneficial ownership, internal controls — while Ireland's transposition of AMLD6 reshapes the supervisory layer around it. Firms should treat 2026–27 as a transition: keep complying with the CJA 2010 today while closing the gaps the AMLR will open.

CompliDesk supports both regimes through the transition, mapping your CJA 2010 procedures to their AMLR equivalents — check whether you are in scope.

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.

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