Designated person

Who is a designated person?

“Designated person” is the Irish statutory label, under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, for anyone carrying on a business that AML law regulates. The list spans credit institutions, funds, payment firms and insurers; solicitors and barristers acting in relevant matters; accountants, auditors and tax advisers; estate agents, letting agents and auctioneers; trust or company service providers (TCSPs); and dealers in high-value goods, among others.

Each sector answers to its own AML supervisor: the Central Bank of Ireland for financial firms, the Law Society for solicitors, the designated accountancy bodies for their members, the PSRA for property services providers, and the AMLCU in the Department of Justice for TCSPs, high-value goods dealers and unaffiliated accountants and tax advisers.

What must a designated person do?

The core obligations are consistent across sectors:

• carry out customer due diligence before establishing a business relationship or handling qualifying occasional transactions;
• run a business-wide risk assessment and risk-rate each client;
• monitor relationships on an ongoing basis and keep CDD and transaction records;
• file suspicious transaction reports to both FIU Ireland (via goAML) and Revenue (via ROS);
• train staff and maintain documented policies, controls and procedures.

Is “designated person” the same as “obliged entity”?

Functionally, yes — with a change of vocabulary on the way. The EU's AMLR, which applies directly from 10 July 2027, uses the term obliged entity for essentially the same population, and widens it: crypto-asset service providers, crowdfunding platforms, letting agents for tenancies with monthly rent of €10,000 or more, and (from 2029) football clubs and agents all come clearly into scope. Irish firms will see both terms used side by side through the transition, and the practical question is not the label but whether your CDD, risk assessment and reporting arrangements meet the incoming standard.

CompliDesk is built for Irish designated persons making exactly that transition — see plans and pricing.