The Irish AML supervisor onboarding checklist
Ireland has no single AML regulator and no AUSTRAC-style enrolment. Instead, a new designated person completes a set of registrations that apply to everyone, then meets the expectations of a sector-specific supervisor. This checklist covers both halves.
Every Irish designated person registers with FIU Ireland’s goAML portal and with Revenue ROS for dual STR reporting, and applies for RBO access using form BEN3A1. Beyond that, your supervisor depends on sector: PSRA for property services, the Law Society for solicitors, the accountancy bodies for their members, the AMLCU for TCSPs, high-value goods dealers and unaffiliated accountants, and the Central Bank for financial firms.
What does every firm need, regardless of sector?
Four items apply to essentially every designated person. Do them first — they take time to approve, and everything else in your AML programme assumes they exist.
- 1
Register with goAML (FIU Ireland)
Register the firm as a reporting entity and your MLRO as a user on the goAML portal via fiu-ireland.ie, so the firm can file Suspicious Transaction Reports. See our step-by-step goAML registration guide.
- 2
Register with Revenue ROS for STRs
Irish STRs are dual-reported: every report also goes to the Revenue Commissioners via ROS as an XML upload (the goAML-generated XML is accepted). Make sure the firm’s ROS access covers STR filing.
- 3
Apply for RBO access with form BEN3A1
Designated persons need restricted Tier 2 access to the Register of Beneficial Ownership to obtain the pre-relationship extract (a flat €2.50 each) and meet the discrepancy-reporting duty under Reg 20(3)(b), SI 110/2019.
- 4
Confirm who your AML supervisor is
Ireland has no single AML regulator — supervision depends on your sector and, for accountants, on body membership. Identify your supervisor before the first inspection letter identifies you.
Step-by-step detail: goAML registration · RBO access via BEN3A1 · STR dual reporting.
What does your sector supervisor expect?
Supervisors publish their own guidance and run their own monitoring, so once the universal registrations are done, your sector determines the rest. Find your row below and start with your supervisor’s AML guidance pages.
Estate agents, letting agents, auctioneers & property management — PSRA
The Property Services Regulatory Authority is both your AML supervisor and your licensing body under the Property Services (Regulation) Act 2011. Keep your property services licence current and check the PSRA’s AML guidance — your licence and your AML obligations are supervised by the same authority.
Solicitors — Law Society of Ireland
The Law Society supervises solicitors for AML and publishes guidance through its AML hub. Expect your AML documentation — risk assessment, policies, CDD files — to feature in the Society’s monitoring of your practice.
Accountants, auditors & tax advisers — designated accountancy bodies
If you belong to a designated accountancy body — Chartered Accountants Ireland, ACCA, CPA Ireland and the other recognised bodies — that body is your AML supervisor, and CCAB-I guidance is the sector reference. Practices not affiliated to any body fall to the AMLCU instead.
TCSPs, high-value goods dealers & unaffiliated accountants — AMLCU
The Anti-Money Laundering Compliance Unit at the Department of Justice supervises these sectors. Note the raised stakes: an administrative financial sanctions regime for the AMLCU has been in force since 30 June 2026 under S.I. No. 307 of 2026. TCSPs should also confirm any authorisation requirements that apply to their activities.
Banks, funds, payments, insurers & CASPs — Central Bank of Ireland
Financial and credit institutions are supervised by the Central Bank, which combines AML supervision with prudential authorisation. Firms in this sector typically face the most detailed supervisory expectations, including on governance and outsourcing.
Does this change under the AMLR and AMLD6?
The substantive rulebook changes on 10 July 2027, when Regulation (EU) 2024/1624 applies directly. The institutional side — who supervises whom, and how national supervisors cooperate — is reshaped in parallel by Directive (EU) 2024/1640, which Ireland transposes, with AMLA in Frankfurt coordinating at EU level. Until your supervisor says otherwise, the registrations and relationships on this checklist stand: they are the plumbing your reporting and register duties run through, under the old framework and the new. Complete them now, keep the confirmations in your compliance file, and watch your supervisor’s guidance pages as 2027 approaches. For the wider run-up, see the 12-month AMLR readiness plan.
Track every registration in one checklist
CompliDesk’s supervisor onboarding checklist tracks goAML, ROS and RBO registrations and your sector-specific items — with the evidence stored where an inspector can follow it.