by John McCarthy Consulting Ltd. | Jan 13, 2026 | Blog, News
The fallout from the Wirecard saga is still ongoing with the latest news on the jailing of two more individuals on 6 January 2026 as reported in the Straits Times (the Times).
The two individuals are Singaporean R. Shanmugaratnam (59), who was earlier was sentenced to 10 years’ jail on Jan 6 and Briton James Henry O’Sullivan, 51, who had abetted Shanmugaratnam, who was sentenced to 6½ years’ in jail. A district court found them guilty of their charges in September 2025 after a trial.
The Times reports that Shanmugaratnam received a request in February 2016, from auditors Ernst & Young (EY) for an entity that he represented called Citadelle to confirm the balance of all accounts held by Wirecard AG and/or its subsidiaries with Citadelle as of 31 December 2015.
Citadelle allegedly confirmed that it held money in escrow accounts for various Wirecard entities across three financial years, but this was not true.
The bottom line for auditors is that verifying the veracity of bank enquiry responses is absolutely critical on audit assignments and more emphasis needs to be placed on following up incorrect or incomplete responses from financial institutions. The relevant Irish audit standard is ISA 505 (March 2024) from the Irish Auditing & Accounting Supervisory Authority
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.
by John McCarthy Consulting Ltd. | Dec 10, 2025 | Blog, News
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:
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. | 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.
by John McCarthy Consulting Ltd. | May 1, 2025 | Blog, News
The new AMLR will have an increased impact on AML governance and responsibilities within firms. It requires:
- a strong internal control framework, including policies, procedures, controls,
- a risk assessment, and
- an independent audit function.
The AMLR also clearly defines
- the compliance manager role and
- the officer role,
- with requirements for their
- appointment
- responsibilities, and
- protection from retaliation.
Strengthened Customer Due Diligence (CDD)
The AMLR largely builds on the existing CDD obligations set out in the 4th AML Directive. The existing transaction threshold that triggers CDD obligations for goods was already reduced from €15,000 to €10,000 since 2010.
Under the new rules, obliged entities carrying out occasional cash transactions that exceed €3,000 will also need to apply client/customer due diligence (CDD) measures.
Accountancy Europe has produced a factsheet that summarises the key provisions of the AMLR and highlights their implications for accountants, auditors, and tax advisors.
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.
by John McCarthy Consulting Ltd. | May 1, 2025 | Blog, News
As reported in Accountancy Europe the new EU Anti-Money Laundering Regulation (AMLR) is a major milestone in the fight against money laundering (ML) and terrorist financing (TF).
The AMLR provides detailed guidance on standard, simplified, and enhanced due diligence measures, including:
- Standard CDD Measures: identifying and verifying customer and beneficial owner identities, understanding the business relationship, monitoring transactions, and identifying PEPs.
- Simplified Due Diligence (SDD): applicable in low-risk situations, allowing for reduced scrutiny measures.
- Enhanced Due Diligence (EDD): required for higher-risk scenarios, including dealings with PEPs, requiring additional information gathering and scrutiny.
Outsourcing
The AMLR introduces new detailed rules for obliged entities that outsource their AML/CFT tasks, distinguishing the term ‘outsourcing’ clearly from reliance on other obliged entities
Enhanced obligations on beneficial ownership transparency
The requirements for due diligence on beneficial owners have been strengthened, with a refined definition of beneficial ownership to clarify the framework for identifying individuals who ultimately own or control legal entities and arrangements. Ownership interest in a corporate entity is determined by a threshold of 25% or more of shares, voting rights, or other ownership interests.
Obliged entities must also verify whether the customer or beneficial owners are subject to targeted financial sanctions (TFS).
A new definition for politically exposed persons (PEPs)
The AMLR expands the definition of PEPs to encompass “heads of regional and local authorities”, as well as “groupings of municipalities and metropolitan regions”. It also specifies that, for the functions of heads of state, heads of government, ministers, deputy or assistant ministers, and equivalent roles at the Union level or in third countries, siblings are also considered ‘family members’.
EU-wide ban for large cash payments
The Regulation imposes an EU-wide maximum limit of €10,000 for cash payments, whether in single or linked transactions. Member States may set lower limits.
Accountancy Europe has produced a factsheet that summarises the key provisions of the AMLR and highlights their implications for accountants, auditors, and tax advisors.
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.
