New AML Laws are Coming Within 16 Months

New AML Laws are Coming Within 16 Months

by | Mar 24, 2026 | Blog, News

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:

  1. 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.

     

  2. 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.
AMLA Progress Report

AMLA Progress Report

by | Dec 10, 2025 | Blog, News

As we reported in April 2025, the AMLA (Anti-Money Laundering Authority) had its first meeting in March 2025. Since then, it has been adding more personnel, growing to a current December 2025 complement of 100 staff (about 20 behind the original plan), with 70 joining in the last three months. The AMLA is based in Frankfurt.

The chair of AMLA is Milanese lawyer, Bruna Szego. Since commencing her role on 1 July 2025, she has visited 25 Member States and met supervisors, Financial Intelligence Units (FIUs), and industry representatives.

On 2 December 2025 she appeared before an EU Parliament Committee (video recording here – start at 10 minutes in) and her key takeaway was that ‘while the financial sector understands its role, the non-financial sector lags behind. The landscape there is fragmented, with many obliged entities facing real challenges in applying even basic controls due to cost and lack of reliable information.’

The future timeline for AMLAs development, according to its own website, is as follows:

  • 2026 – Gradual ramping up of IT business service and assessment of AMLA’s future IT needs
  • 2027 – 40 obliged entities are selected to be directly supervised
  • 2027 – at the end of 2027 AMLA staff reaches a cruising capacity of about 430
  • 2028 – Start of direct supervision, with AMLA fully operational

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:

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.

AMLA Starts Operations

AMLA Starts Operations

by | Apr 18, 2025 | Blog, News

In case you haven’t already heard designated persons (that includes accountants in practice) have a new regulator called the ‘Authority for Anti-Money Laundering and Countering the Financing of Terrorism’. Originally created in June 2024, the Board held its first meeting in March 2025 and the chair is Bruna Szego.

The aim of this new authority is to coordinate national AML authorities around Europe to ensure the correct and consistent application of AML rules in each jurisdiction.

AMLA will also supervise supervisory bodies in Europe including the Institute and enhance cooperation among police financial intelligence units (FIUs).

Ms Szego will be at the RDS in Dublin in May to give the Keynote Address at the European Anti-Financial Crime Summit 2025.

It’s expected that AMLA will be fully operational by 1 January 2028 with a staff complement of 430.

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:

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.