The firms that build company structures face the sharpest scrutiny
Company formation agents, registered-office providers, and nominee and trustee service providers have been designated persons under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010) for over a decade. From 10 July 2027, Regulation (EU) 2024/1624 (AMLR) replaces that rulebook — directly applicable, no Irish transposition. CompliDesk gets your firm AMLR-ready.
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TCSPs answer to the AMLCU — and its enforcement powers are set to grow
Trust & company service providers are supervised for AML by the Anti-Money Laundering Compliance Unit (AMLCU) at the Department of Justice — not the Central Bank, and not a professional body. That distinction matters, because the enforcement landscape for the AMLCU’s sectors is changing before the AMLR even arrives.
Administrative financial sanctions — in force since 30 June 2026
An administrative financial sanctions regime for the AMLCU’s sectors commenced on 30 June 2026 (S.I. No. 307 of 2026). Enforcement has teeth before the AMLR applies — the gap between a weak AML programme and real consequences has closed early for TCSPs.
Ireland’s AML/CFT Action Plan 2026–2027
Ireland has published an AML/CFT Action Plan for 2026–2027. The direction of travel is set: supervision is tightening through the run-up to 10 July 2027, not after it. Firms that wait for the AMLR to apply before refreshing their programme will be doing it under a more active supervisor.
Why TCSPs sit in the spotlight
Beneficial-ownership transparency is the heart of the AMLR. The whole architecture — the 25% rule, registers, discrepancy reporting — exists to answer one question: who really owns and controls this structure? For a TCSP, that question runs through every file you hold.
The 25% rule, harmonised EU-wide
Under the AMLR, a beneficial owner is anyone holding 25% or more of a company, directly or indirectly — one definition across all 27 member states. The Commission may later set a lower threshold, to 15% or lower, for high-risk sectors by delegated act following a review due by 2029.
RBO duties are already live
Since April 2021, designated persons must obtain an RBO extract before entering a new business relationship, and must report discrepancies between the register and what they actually find (Reg 20(3)(b), SI 110/2019). Every entity you form or administer passes through this check.
Your services are the test case
Company formation, registered offices, nominee directorships and trustee arrangements are exactly the structures the beneficial-ownership rules exist to make transparent. Supervisors look hardest at the firms that build and maintain them — that is your day job.
What the AMLR changes for your firm
The AMLR replaces the substantive rulebook your CJA 2010-era programme was built on. “Designated persons” become “obliged entities”, and the detail changes underneath you.
How CompliDesk helps TCSPs
One system for every entity your firm forms or administers — from onboarding and ownership mapping through screening, risk assessment and reporting.
Entity onboarding with KYB
Structured due diligence for corporate clients: business verification with CRO company lookup, plus biometric identity verification (Didit) for the individuals behind each entity.
Ownership-structure mapping
Build a corporate ownership tree for every client structure, aligned with the AMLR’s 25% UBO logic — so who ultimately owns what is documented, not assumed.
RBO extract workflow
A guided workflow prompts the RBO extract before each new business relationship, stores the evidence, records the comparison against what the client told you, and logs your discrepancy decision.
Sanctions & PEP screening
Screen owners, directors and nominees against the EU consolidated financial sanctions list, UN listings and PEP databases via OpenSanctions — with a full decision log.
BWRA & AMLR policy pack
Generate your Business-Wide Risk Assessment and AMLR-aligned policies, controls and procedures, with fields to designate your compliance manager and compliance officer.
STR builder & dual tracker
Build the STR, export goAML-compatible XML, and track both submissions — FIU Ireland via goAML and Revenue via ROS — with dates and acknowledgements in one place.
Audit trail throughout
Every check, decision and document is time-stamped against the client file, with 5-years-then-delete retention built in — so an AMLCU inspection request is an export, not a scramble.
CompliDesk records and prepares — it does not file STRs on your firm’s behalf. RBO access is a guided workflow with evidence storage; the register has no public API.
Ready your TCSP practice before 10 July 2027
The full platform launches well before the AMLR applies. Readiness services and free early access are available now — join while it’s free and lock in founding-member pricing at launch.
Or start with the free AMLR Readiness Checklist (PDF).