The Department of Justice recently published Ireland’s 2026 AML National Risk Assessment in advance of a FATF inspection expected in 2028. The last such assessment was carried out in 2019.
Noteworthy is the fact that the AML risk of the accountancy sector has changed from ‘Medium-High’ to ‘Significant’ as follows:
Risk Rating
Key to the chart:
ML = Money Laundering
TF = Terrorist Financing
PF = Proliferation financing
AML Threats for the Accounting Profession
The document explains that accountants are exposed to significant ML and TF risks due to the sector’s accessibility, diversity, and the breadth of services offered.
Criminals may exploit accountants not only to lend legitimacy to illicit transactions, but also to enhance the overall credibility and respectability of illegitimate business activities. The involvement of a qualified and professional accountant can create a veneer of legitimacy that helps obscure the true nature of criminal enterprises.
This can occur through services such as bookkeeping, payroll, tax advice, and the use of accountant’s certificates to support falsified documentation, making illicit operations appear compliant and trustworthy to third parties. The risk is elevated in cases involving cash-intensive businesses, where criminal proceeds can be more easily co-mingled with legitimate income.
When delivered effectively and in line with the ML regulations, accountants play a vital role in safeguarding against economic crime, however, weak or poorly implemented AML controls can be targeted by criminals. In rare but serious instances, there is also a risk of infiltration by criminal organisations, or corruption of staff within legitimate firms. Accountants that provide TCSP services face additional exposure, while those offering audit services play a key role in identifying and preventing economic crime.
There has been no evidence to suggest that Accountants are being exploited for PF purposes, and the sector’s exposure is therefore assessed as low. Nonetheless, continued vigilance is essential, particularly where services intersect with high-risk jurisdictions or involve complex corporate structures.
All the templates on our website have had a refresh as of June 2026 and the letters of engagement have had a new paragraph added for the potential use of artificial intelligence and machine learning on client assignments along with auto enrolment for payroll assignments. There is a bulk discount (five templates for the price of four) for purchases of five or more templates when purchased in a single transaction.
If you need an up-to-date engagement letter, there is a search bar near the bottom of our home page (www.jmcc.ie) to quickly look up the item you need. More details see here.
For those of you still in the process of ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.
We typically tailor our training and brainstorming sessions to suit each firm’s unique requirements.
Publications:
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- The ISQM TOOLKIT 2022 is available to purchase here.
- See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
- To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together
