Although published in July 2025, the 2024 Annual Report of the Department of Justice AML Compliance Unit (AMLCU) did not attract the attention it deserved at the time.
While the overall number of AML reports fell by 12% (60,753 versus 68,998 in 2023) compared to the 2023 level, the numbers of AML reports from accountants doubled to 30. AML reports from auditors are recorded separately and there were 10 of those in 2024.
The number of AML reports from accountants in the last five years were as follows:
- 2024 – 30
- 2023 – 15
- 2022 – 9
- 2021 – 33
- 2020 – 11
While most accountants are inspected for AML purposes by their professional body, those self-employed accountants not already supervised by a professional body are inspected by the AMLCU and in 2024, 81 were inspected, including tax advisors.
The results of these 81 inspections in 2024 are as follows:
| Compliant | Partial | Non-Compliant | N/A, Other* | |
| External Accountant | 20 | 14 | 4 | 16 |
| Tax Advisor | 7 | 3 | 2 | 15 |
| 27 | 17 | 6 | 31 |
- *Other includes: Not a designated person; unannounced inspections of a suspected TCSP operating without authorisation; entity no longer trading.
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
- Our latest CPD Webinar on The Main Changes in Irish GAAP (recorded July 2024)
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion you receive a CPD certificate for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
