Boats, Yachts and AML

Boats, Yachts and AML

by | Oct 15, 2025 | Blog, News

Do you have a client business that deals or sells in boats or yachts where they may handle cash as part of the transaction?

Did you know that where the cash element of the transactions exceeds €10,000 in one single transaction or in a series of linked transactions, that your client is deemed to be a high value goods dealer (HVGD) and is obliged to register with the Department of Justice Compliance Unit (AML Unit) known as the AMLCU?

The AMLCU website also contains a downloadable Business Risk Assessment template which must be competed by your client annually under Section 30A of the Criminal Justice (Money Laundering & Terrorist Financing) Acts, 2010 to 2021.

As well as registering with the AML Unit, Customer Due Diligence must be applied to the transactions (meaning completing a written risk assessment and obtaining:

  • a copy of the customer’s photo I.D. (i.e. a passport or driving licence) and
  • a recent utility bill in the name of the customer.

The following documentation requirements also apply to the business:

  1. Keep the sales order for inspection by the AMLCU.
  2. Retain records of the method of payment (e.g. cash, cheque, EFT, etc.).
  3. Complete the cash transaction form designed by the AMLCU for those transactions of €10,000 or more.
  4. All documentation relating to transactions must be retained for the lifetime of the customer plus 5 years after that.
  5. Maintain an anti-money laundering (AML) file containing information on money laundering e.g. policies, guides, correspondence, etc.
  6. Have a written policy statement on money laundering and
  7. Evidence of recent up to date AML training for all staff.

If your client considers that one of their customers is involved in a suspicious transaction, they are obliged to report it to the Financial Intelligence Unit (FIU) and to the Revenue Commissioners through the relevant reporting channels.

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.

The CRBOT

The CRBOT

by | Oct 6, 2025 | Blog, News

The CRBOT (Central Register of Beneficial Ownership of Trusts) was created in 2021 to help prevent money laundering and terrorist financing through the use of trusts. It is a register of the names and details of the ultimate beneficial owners of Irish trusts.

In recent years the Revenue Commissioners are concerned that not every trust that should be registered on the CRBOT is actually on the register.

Their CRBOT Team have been conducting compliance-related visits to those acting for trusts, e.g. trust service providers, to ensure they are complying with the CRBOT requirements. While this will apply more to solicitors and law firms, some accountants may also act as trust service providers

The Revenue say that there is a general lack of awareness of CRBOT e.g.:

  • The term ‘beneficial owner’ means more than just a beneficiary/ class of beneficiaries.
  • The CRBOT Team expect to see a ‘settlor’, so a will trust, or unilateral trust should include this status in the trustee’s nature and extent of interest held.
  • Designated persons must check the CRBOT register themselves and retain evidence of that check.
  • Where a company acts as a beneficial owner and is registered on the RBO (Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies), their CRO number can be provided to avoid capturing data that is already on the RBO.

Discrepancy Notices must be submitted if designated persons (such as tax advisers) identify factual discrepancies in relation to the trust registers when performing AML due diligence required under AML requirements.

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.