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. | Aug 13, 2025 | Blog, News
In this second of two blogs, we look at the impact of the leasing changes to FRS 102 coming soon. Last week we looked at the main balance sheet impact. This week we look at the P&L impact.
The familiar rent expense in the P&L will largely disappear and will be replaced by:
- Depreciation of the ROU asset, along with an
- Interest expense for the lease liability.
The impact of these changes will often result in a higher EBITDA (Earnings Before Interest, Tax, Depreciation, and Amortisation) as lease costs move from operating expenses to depreciation and finance costs.
The other impacts will be:
- Businesses, not for profit entities and charities with loan agreements tied to financial covenants (e.g., debt-to-EBITDA ratios, interest cover) will need to carefully assess the potential impact of these changes. The sooner they start having conversations with lenders the better.
- An increase in reported assets could push some businesses over the audit exemption size thresholds, potentially triggering the requirement for a statutory audit.
Work to be done:
The preparatory work to be done in advance of 1 January 2026 will include:
- Identifying all affected lease contracts
- Identifying leases ‘hidden’ within service agreements
- Obtaining detailed information from lease agreements so as to have an accurate calculation of the ROU asset and lease liability along with the payment schedules, extension options, and an appropriate discount rate.
This change in Irish GAAP lease accounting is a significant one, promising more transparency but also requiring advance preparation. The sooner the changes are understood, the sooner businesses and charities/not for profit entities can plan to ensure effective compliance by the application date.
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. | Aug 13, 2025 | Blog, News
In this first of two blogs, we look at the impact of the leasing changes to FRS 102 coming soon.
For accounting periods commencing on 1 January 2026, lease liabilities for most entities will now be on the balance sheet at 31 December 2026 and could spell trouble for EBITDA, loan covenants, and audit thresholds. The changes do not apply to micro entities (if they qualify to apply FRS 105).
Heretofore many businesses in Ireland have enjoyed the relative simplicity of ‘off-balance sheet’ accounting for their operating leases where a rent expense hit the P & L account, and for a multitude of entities, that was the end of the matter.
However, there is a significant change coming soon for Irish Generally Accepted Accounting Practice (known as Irish GAAP) under the Financial Reporting Standard (FRS) 102, bringing the treatment of lease accounting more in line with the international standard, International Financial Reporting Standard (IFRS) 16 Leases.
The good news is that there is some time to prepare, but not too long as there needs to be advance preparation but only four months at this stage.
The main change is that FRS 102 introduces the concept of the ‘right-of-use’ (ROU) model for lessees, largely based on IFRS 16 and virtually all leases will come on balance sheet. Businesses and charities will soon be required to recognise:
- A Right-of-Use (ROU) Asset: This asset represents the lessee’s right to use the leased asset over the lease term. It will appear on the balance sheet, typically alongside property, plant and equipment; and an equivalent
- A lease liability: This liability represents the obligation to make lease payments over the lease term. It will also be recognised on the balance sheet, divided into current and non-current portions.
Impact on financial statements
The impact of this change will be significant for many businesses and not for profit entities, particularly those with a substantial portfolio of operating leases. Examples include:
- Retailers with multiple leases,
- Manufacturers leasing machinery and
- Logistics firms with rolling fleet contracts.
These businesses can expect their balance sheets to grow, with an increase in both assets (ROU assets) and liabilities (lease liabilities). This will change key financial ratios, such as
- leverage and
- debt-to-equity.
More on this topic next week.
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. | Aug 8, 2025 | Blog, News
As we forecast in our 1 July blog, the Financial Reporting Council published new draft guidance to assist auditors of Smaller Less Complex Entities with the audit process.
The new Practice Note (PN) is called ‘Guidance for Auditors of Smaller Less Complex Entities’ loosely based on the well-loved Practice Note 26 ‘Guidance on Smaller Entity Documentation’, which was withdrawn in 2018. It contains some of the examples from the original PN 26 updated for the latest trends in accounting software by including mention of Xero and Quickbooks.
PNs are well regarded among the audit profession as indicative of best practice and are intended to assist auditors and regulators alike, in applying auditing standards of general application to particular circumstances and industries and are regarded as persuasive rather than prescriptive. According to the Financial Reporting Council, the draft PN may already be used in helping auditors to determine what best practice audit documentation should look like in the audit of a small or less complex entity.
This PN is designed to assist auditors in applying auditing standards of general application to particular circumstances and industries.
The draft PN is available for consultation until 17 October 2025, and the final version should be published by Q4 of 2025.
According to the draft PN the characteristics that typically define smaller and/or less complex entities are:
- Ownership and control are often concentrated among a few individuals.
- Operations are uncomplicated, with limited sources of income and activities.
- Business processes and accounting systems are simple, with few internal controls.
- Entities may include small companies, charities, and larger entities with simple structures.
- Complexity may arise in specific areas, such as accounting estimates, even in otherwise simple entities.
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.
