by John McCarthy Consulting Ltd. | 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:
- 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.
by John McCarthy Consulting Ltd. | Mar 21, 2026 | Blog, News
If you have clients in the high value goods dealer (HVGD) sector, then you will need to be aware of this case.
According to the website of the AML Compliance Unit of the Department of Justice HVGDs ‘are businesses involved in the sale of goods of high value where the trader accepts cash payments of €10,000 either in one transaction or a series of linked transactions. Examples of these businesses include antique dealers, boat and car sales, dealers in precious stones, jewellers.’
In a recent February 2026 case the Dutch branch of Louis Vuitton suffered a €500,000 penalty in an out of court settlement, for significant violations of the Money Laundering and Terrorism Financing Prevention Act in the Netherlands.
The underlying criminal case against the three individuals involved remains active, reflecting a trend where regulatory authorities often prioritize corporate accountability through financial sanctions while simultaneously pursuing criminal prosecutions against the specific actors who orchestrated the laundering scheme. The three main suspects face prosecution in a Rotterdam court.
The sanction followed a comprehensive police investigation into a sophisticated money laundering network that utilized luxury retail channels to disguise the origins of criminal proceeds.
The company was found guilty of falling short of the AML requirements by allowing a single customer to conduct a series of high-value transactions without triggering the necessary internal red flag alerts or verification procedures. The failure to monitor and report suspicious activity enabled a criminal organization to convert more than €2 million in cash payments over a multiyear period from 2021 to 2023.
HVGD retailers are expected to not only:
- Identify their customers, but also
- Investigate the source of funds when transactions meet certain risk profiles.
In this case, Louis Vuitton allegedly ignored multiple red flags, including the frequent use of different aliases by a recurring customer and the sheer volume of physical currency being exchanged for designer handbags. The acquisition of these goods was not for personal use but was instead a critical step in a value transfer process known as the Daigou trade. The UK National Crime Agency produced a detailed report on the Daigou AML phenomenon in 2019.
The Daigou model involves the purchase of luxury items in Western markets for resale in territories where such goods are more expensive or heavily taxed, such as China. The use of luxury retail items as a vehicle for laundering is particularly attractive to criminal groups because these products maintain high resale value and are easily transportable.
From 1 January 2026, the Netherlands has implemented a ban on accepting cash payments of €3,000 euros or more for professional sellers of goods. This same €3,000 threshold will apply in Ireland once legislation enacting the 6th AML Directive comes into force within the next two years.
This legislative change is specifically designed to eliminate the room for manoeuvre previously enjoyed by those who structured payments just below the old €10,000 threshold, which still applies in Ireland for the time being.
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.
by John McCarthy Consulting Ltd. | Mar 7, 2022 | Blog, News
On Friday 4 March 2022 the Consultative Committee of Accountancy Bodies in Ireland (CCAB-I) issued updated guidance applicable to accountants in practice for immediate use.
The Guidance is a widely respected and hugely valuable document among accountants as it sets out the minimum criteria that must be adhered to in order to comply with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021 (‘the Act’) in the Republic of Ireland.
Key changes in the legislation are reflected in additional guidance in areas such as:
- Greater emphasis on identification of beneficial owners of businesses;
- Expanding the definition of tax adviser, letting agent and intermediaries at art auctions;
- The definition of a Politically Exposed Person (PEP) to include any individual performing a prescribed function;
- There is a specific list of enhanced due diligence measures that the designated person is required to apply when dealing with a customer established, or residing, in a High-risk third country;
- The new requirement in place since 23 April 2021 that prior to commencing a business relationship is established, reasonable steps must be taken to verify the beneficial ownership of corporate clients including confirming the beneficial ownership with the relevant Central Register. Where a Designated person identifies a ‘discrepancy’ (as defined) in the Act, i.e. where the entry is inconsistent or incorrect between its own records and those maintained by the Central Register, it must notify the relevant Registrar.
- There is a similar requirement to notify the relevant Registrar where there is evidence of ‘non-compliance’ (as defined) in the Act, i.e. where the register is blank, it must notify the relevant Registrar.
A copy of the guidance may be accessed here.
Specially tailored up to date AML Training that meets the requirements of the legislation is available on request, on Zoom, in person or as a hybrid event, with a free video recording supplied afterwards, for future viewing. Contact john@jmcc.ie for further details.
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.
For our latest Audit Quality Control Manual (October 2021) (implementing the latest Irish Audit & Accounting Supervisory Authority standards including ISQC1 on audit quality control) click here. View the Table of Contents here.
We also have an up to date Anti-Money Laundering Procedures Manual (September 2021) – View the Table of Contents click here.
