Conveyancing, probate, company and trust work — under a new AML rulebook

Supervision by the Law Society

The Law Society of Ireland is the AML supervisor for solicitors. It monitors how firms meet their anti-money-laundering obligations and can examine your firm’s compliance — so your CDD files, risk assessment and policies need to stand up to a professional reviewer who knows practice inside out.

The sector reference: the Law Society AML hub

The Law Society’s AML hub on lawsociety.ie is the sector’s reference point for guidance. CompliDesk is built to sit alongside it: the software handles the workflow and the evidence, while your firm follows the Society’s guidance on the law.

CDD on conveyancing — both sides of the deal

Property work means due diligence on the client in front of you, whether they are selling or buying. Vendor and purchaser matters each need identity verified, ownership understood and the file able to show it — before the matter moves, not after.

The client account

Deposits, completion monies and estate funds pass through your client account. Every movement should trace back to an identified client and a documented purpose, so the account never becomes the weak point in your firm’s AML file.

Company and trust work

Forming companies, acting in trust matters and advising on ownership structures all raise beneficial-ownership questions. You need to identify who ultimately owns or controls the structure, and reconcile that against Ireland’s beneficial-ownership registers.

Source of funds on property transactions

Where is the purchase money coming from? On property matters that question has to be asked, answered and evidenced — savings, sale proceeds, gifts, loans — with the supporting documents held on the file.

Occasional-transaction CDD at €10,000

The customer due diligence threshold for occasional transactions drops to €10,000, from €15,000 — and occasional cash transactions of €3,000 or more trigger limited CDD. Thresholds your precedents assume today will be out of date.

The 25% beneficial-ownership rule

A beneficial owner is anyone with 25% or more ownership interest, direct or indirect — harmonised EU-wide under the AMLR. Your company and trust files need to reflect that test consistently.

RBO extracts and discrepancy duties

Before entering a new business relationship you must obtain an RBO extract and report discrepancies between the register and what you find (Reg 20(3)(b), SI 110/2019). Your firm registers for designated-person access via form BEN3A1. These duties carry across under the new framework.

Prescribed compliance roles

The AMLR requires a board-level compliance manager plus a compliance officer of sufficiently high standing. From 10 July 2027 the compliance officer also becomes responsible for implementing targeted financial sanctions.

STR dual reporting stays

Suspicious Transaction Reports are dual-reported in Ireland: to FIU Ireland via the goAML portal, and to the Revenue Commissioners via ROS as an XML upload. Your MLRO must be registered on both.

EDD for high-net-worth clients — and retain-then-delete

Enhanced due diligence applies to high-net-worth relationships — assets of €5m or more handled for a client whose total wealth is €50m or more. And records must be retained for five years, then deleted: retention alone is no longer enough.

Run client due diligence as part of opening the matter, not as a separate chore. Identity, ownership and risk decisions sit on the record they relate to, captured once and to the AMLR thresholds.

Verify individual clients and corporate or trust clients through Didit’s KYC and KYB identity verification — consistent evidence for vendors, purchasers, executors and directors alike.

A guided before-new-client workflow: obtain the RBO extract, store it, record the comparison against what the client told you, and log the discrepancy decision — a clear trail from register to file.

Screen clients and beneficial owners against the EU consolidated financial sanctions list, UN lists and PEP datasets via OpenSanctions — at onboarding and on an ongoing basis.

Generate a Business-Wide Risk Assessment and policy pack mapped to Regulation (EU) 2024/1624, including the compliance manager and compliance officer role designations the AMLR prescribes.

Build the STR record, export goAML-compatible XML for upload to goAML and Revenue ROS, and track both submission dates and acknowledgements. CompliDesk prepares and records — your MLRO files.

A full audit trail behind every compliance action, plus a staff training log — so when the Law Society reviews your firm’s AML compliance, the evidence is organised and ready to hand over.