On 13 August 2026, the Minister for Finance published the first national strategy to strengthen Ireland’s fight against money laundering, terrorist financing and proliferation financing (ML/TF/PF) (Strategy).
This article sets out the key elements of the Strategy relevant to the financial services sector.
Overview of the Strategy
The Strategy covers the period from 2026 to 2030 and takes account of the recently published National Risk Assessment on AML/CFT/CPF 2026 (NRA) and related priority action implementation plan. It aims to ensure the safety and security of citizens and protect the integrity and stability of the Irish financial system. Underpinning the Strategy and its objectives is Ireland’s anti-money laundering, counter-terrorist financing and counter-proliferation financing (AML/CFT/CPF) framework. The framework is designed to ensure that State responses to ML/TF/PF are targeted, proportionate and focused on areas of greatest risk, in line with national and EU obligations.
The Strategy sets out:
- the components of Ireland’s AML/CFT/CPF framework (see below)
- the current ML/TF/PF threat landscape in Ireland
- the government departments and agencies, competent authorities, law enforcement authorities, private sector entities and public-private partnerships that have a role in achieving the Strategy’s objectives
- the international and EU organisations that Ireland engages with for AML/CFT/CPF purposes
- the government’s strategic goals for strengthening Ireland’s AML/CFT/CPF framework, together with specific actions related to each goal (see below)
While the Strategy takes a whole-of-government approach, focusing primarily on the roles of government departments and competent authorities, successful implementation will rely on strong co-operation across a wide range of public and private sector partners, including credit and financial institutions.
Ireland’s AML/CFT/CPF framework informing the Strategy
The Strategy identifies three interconnected pillars of Ireland’s AML/CFT/CPF framework:
- Policy and oversight: Assessing ML/TF/PF risks, developing domestic and EU-aligned policy, and ensuring strategic oversight and co-ordination across government and competent authorities.
- Safeguarding and monitoring: Safeguarding, promoting, supervising and monitoring AML/CFT/CPF compliance, and collecting, analysing and disseminating financial and related intelligence.
- Investigation and enforcement: Identifying, investigating, prosecuting and sanctioning ML/TF/PF offences.
The Strategy indicates that the following elements contribute to the effectiveness of Ireland’s AML/CFT/CPF framework across all three pillars:
- Legal measures: Ireland’s AML/CFT/CPF framework is currently underpinned by the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010). The CJA 2010 is reinforced at a domestic level by regulations and guidance, including guidance issued by the Central Bank of Ireland (CBI). At a global level, the framework is supported by the Financial Action Task Force (FATF) Recommendations and EU and UN measures, for example. However, the legal framework will be significantly revised after the EU’s new AML/CFT legislative package comes fully into effect / is transposed over the next few years. For example, Regulation (EU) 2024/1624 (AML Regulation), which will have direct effect in Ireland, will primarily apply from 10 July 2027 and Directive (EU) 2024/1640 (AMLD6) must be transposed by 10 July 2027, save for a small number of exceptions.
- Strong collection and use of financial intelligence among relevant stakeholders: This helps ensure high-quality reporting to FIU Ireland and the Revenue Commissioners, supporting investigative priorities, target identification and asset tracing.
- Adapting to new threats and evolving risks: This requires close co-ordination between public and private-sector partners, sufficiently resourced and skilled law enforcement authorities, a legal system that provides clear deterrents and robust supervision that ensures effective compliance by designated persons.
The Strategy aims to strengthen these three elements to ensure that Ireland’s AML/CFT/CPF framework is robust and continues to prevent, detect and disrupt illegal financial activity.
Strategic goals and actions in the Strategy
As mentioned above, the Strategy outlines the government’s strategic goals to strengthen Ireland’s AML/CFT/CPF framework, together with specific actions. The five strategic goals and associated actions relevant to the financial services sector are set out below.
1. Strengthening national co-ordination
- The State’s Anti-Money Laundering Steering Committee (AMLSC) will be responsible for overseeing and co-ordinating implementation of the Strategy.
- Regarding TF and PF, a CFT/CPF subgroup of the AMLSC has been established, consisting of government departments, law enforcement authorities and competent authorities. The subgroup will assess the latest TF/PF threats and vulnerabilities in Ireland.
- The AMLSC will plan for new or revised domestic and EU legislation. This will involve early identification of, and co-operation between, impacted government departments and state agencies.
- Enhanced arrangements between competent authorities and law enforcement authorities will be established to better facilitate information sharing on ML/TF and sanctions evasion risks.
2. Better identification, assessment and understanding of ML/TF/PF risks
- Enhanced data collection and analysis of ML/TF/PF threats and vulnerabilities sourced from suspicious transaction reports (STRs), investigations, prosecutions, convictions and asset seizures will be implemented. This will include enhancements to FIU Ireland’s STR collection toolkit to allow for improved analytical capabilities and an enhanced ML/TF analytical capacity for the Office of the Director Public Prosecution.
- The Department of Finance (DoF) will lead discussions to consider the feasibility of introducing a mandatory registration requirement with FIU Ireland for persons subject to reporting obligations.
- The CBI should enhance data collection on ML/TF and financial sanctions evasion risks via the rollout of its updated risk evaluation questionnaire (REQ) on a sector-by-sector basis. It should also undertake targeted analysis of sectors and products, including cross-border financial flows, to identify vulnerabilities and threats.
3. Delivering a stronger regulatory framework
i. Implementation of the EU’s AML/CFT legislative package
- Following the establishment of a cross-departmental transposition working group in 2024, work on transposing legislation for AMLD6 has begun. Transposition will primarily involve amendments to the CJA 2010 and related statutory instruments.
- Consideration is being given to the impact of the AML Regulation on Ireland’s AML/CFT framework and the necessary changes required to support competent authorities’ and FIUs’ existing roles and their co-operation with the new EU Anti-Money Laundering Authority (AMLA).
- Legislation to fully implement Regulation (EU) 2023/1113 (the revised Funds Transfer Regulation) is well advanced.
ii. Beneficial ownership
- Two sets of statutory instruments to amend the European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2019 and the European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 were published this summer (S.I. No. 406/2026 and S.I. No. 335/2026). The two statutory instruments transpose Articles 11, 12, 13 and 15 of AMLD6 into Irish law, amending domestic requirements relating to access to beneficial ownership information held on Ireland’s beneficial ownership registers for corporates and trusts. The revised rules are in force.
- Legislation to transpose Articles 11, 12, 13 and 15 of AMLD6 in relation to the beneficial ownership register for certain financial vehicles will be published in due course.
- The DoF will seek to introduce mandatory disclosure of the ultimate beneficial owners and controllers of all limited partnerships.
iii. Role of the CBI
- The CBI should continue to use its full regulatory and supervisory toolkit to ensure that the financial services sector identifies and mitigates ML/TF and financial sanctions evasion risks. In particular, it should:
- develop an understanding of how new and emerging technologies (including AI) create vulnerabilities and present opportunities for improved AML/CFT systems and controls and share this understanding with firms
- set out its expectations for firms regarding their AML/CFT governance, risk management and wider control frameworks to keep pace with the criminal deployment of new and emerging technologies
- ensure that greater use of technology is integrated into its regulatory and supervisory activities
iv. Special purpose entities
- The DoF will introduce legislation to enable the Revenue Commissioners to publish a list of special purpose entities availing of the ‘section 110 regime’ under the Taxes Consolidated Act 1997.
- The DoF will also seek to implement a requirement for a legal entity identifier on entities availing of the ‘section 110’ designation.
4. Building capability and outreach
- The CBI should provide periodic, structured feedback to sectors and firms on ML/TF and financial sanctions evasion risks, building on enhanced REQ data and supervisory engagement with firms. Firms should incorporate this feedback into their AML/CFT business-wide risk assessments and AML/CFT systems and controls.
- Private-sector partnership will continue to be critical to the early detection of suspicious activity and emerging threat patterns. This partnership will be continued and strengthened through various fora, such as financial services sector engagement with the CBI on several private sector initiatives.
5. Enhancing international cooperation
- Ireland will deepen its international AML/CFT/CPF co-operation by engaging actively with AMLA, Europol, Eurojust and the European Central Bank, strengthening its role in the Egmont Group, maintaining compliance with sanctions regimes, preparing for its 2028 FATF Mutual Evaluation, and engaging with the International Monetary Fund’s AML/CFT Thematic Fund.
How ALG can help
Our Financial Regulation Advisory Team is advising clients on the implications of the EU’s AML/CFT package on their businesses, including changes to client due diligence measures, business-wide risk assessments, group-wide requirements and outsourcing obligations. We can assist firms in understanding these developments and assessing their impact on their policies, procedures, systems and controls. We are well placed to help firms prepare for the next phase of AML/CFT regulatory change and ensure that their AML/CFT frameworks remain fit for purpose.
Conclusion
Ireland's first national AML/CFT/CPF Strategy provides a clear roadmap for how the State intends to strengthen its response to ML/TF/PF over the period to 2030. While many of the actions are directed at government departments, competent authorities and law enforcement authorities, the Strategy also signals heightened expectations of regulated firms, particularly in relation to risk assessment, governance, information sharing and the use of technology. Against the backdrop of the EU's AML/CFT legislative package and anticipated supervisory scrutiny, regulated firms should continue to monitor developments closely and assess whether their AML/CFT frameworks are suitably positioned for the evolving regulatory landscape.
For further information on the Strategy or the EU’s AML/CFT legislative package, please contact Eoin O’Connor, Partner, Patrick Brandt, Partner, Eimear O’Brien, Partner, Louise Hogan, Partner, Sarah Lee, Senior Practice Development Lawyer or your usual ALG contact.
Date published: 19 August 2026
