New anti-money laundering (AML) legislation is expected to be enacted in Ireland in at least two tranches on or before 10 July 2026 and 10 July 2027.
In this blog and in the coming weeks we summarise the points of most interest to accountants in practice, based on the Technical Alert 05/2025 (TA) issued by Chartered Accountants Ireland in December 2025. There are more details in the TA itself.
These AML laws will complete the implementation of the European Union 6th Anti Money laundering package which was enacted by the EU on 9 July 2024.
These laws comprise two parts:
- A Regulation called the AML Regulation (EU) 2024/1624) which is about the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
- A Directive called the AML Directive (EU) 2024 /1640) on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
As we know from the GDPR (Data Protection Regulation from 2018) regulations must be implemented across the EU Member States without any local changes, whereas Directives permit some minimal local variation.
These new rules will be overseen by the new Europe wide AML Regulator called the Anti-money Laundering Authority (AMLA).
For the time being accountants should refer to the existing up to date AML guidance for accountants in Ireland called Technical Release 01-2019 (Updated March 2022) AML Guidance for CCAB-I members. This guidance will need refreshed when the new legislation comes into effect.
The main changes coming into place include:
- Independent Audit Function – As part of the accountancy firm’s internal policies, procedures and controls entities are required to have in place an independent audit function to test the internal policies and procedures and the controls in place in the firm. Where such an independent audit function is not present within the firm, it may have the test carried out by an external expert.Firms must ensure that the person responsible for the AML audit function can report directly to the management body. Independent audit appears to be mandatory under the AML Regulation.
Firms will also be required to take measures to ensure employees, agents and subcontractors like are aware of AML requirements and these measures include participation of those employees, agents and subcontractors in specific ongoing AML training programmes that show them how to recognise operations which may be related to money laundering or terrorist financing and to show them how to proceed in such cases.
- Integrity and Honesty Assessment – Article 13 of the AML Regulation requires firms to assess employees, agents and subcontractors who directly participate in the firm’s AML compliance functions as having appropriate skills, knowledge and expertise to carry out their functions effectively including an assessment of their honesty and integrity and whether they are of good repute.
How can John McCarthy Consulting help?
Our audit file review service is available either on-site or remotely where we will provide you with a written report benchmarking your audit file against the appropriate standards. You will receive a gap analysis of where your firm stands on a particular assignment within clear direction as to appropriate action to consider for improvement.
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:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- 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.
