knowledge 21 August 2026 |

Understanding Ireland’s National AML/CFT/CPF Strategy

Given Ireland's open economy and its integration into the EU single market, a broad range of sectors are subject to anti-money laundering (“AML”), counter-terrorist financing (“CFT”) and counter-proliferation financing ("CPF”) legislation and requirements. Proliferation financing is defined in the National Strategy as “the provision or movement of funds or assets to support the proliferation of Weapons of Mass Destruction (“WMD”), including related materials and delivery systems.”

 The National Strategy builds on the findings of the 2026 National Risk Assessment and its Priority Action Implementation Plan, (see our previous briefing “Know Your Risk: What Ireland’s 2026 AML/CFT/PF National Risk Assessment and Action Plan Mean for Firms.”)

The Three Pillars

The National Strategy's framework is underpinned by three interconnected pillars:

1. Policy and Oversight
2. Safeguarding and Monitoring
3. Investigation and Enforcement

For AML/CFT measures to be effective, designated persons subject to the rules must fulfil their obligations and recognise their role in identifying and preventing ML and TF.  These obligations must be clear, consistent and proportionate, with a risk-based approach aligned with EU and the Financial Action Task Force (“FATF”) standards helping ensure resources are focused on the areas of greatest risk while minimising unnecessary regulatory burden.

Five Strategic Goals

The National Strategy sets out five strategic goals to strengthen Ireland’s AML/CFT/CPF framework and address issues identified through national assessments and reviews:

1. National Coordination

Strengthen national coordination and oversight through effective cross-border collaboration, with the Anti-Money Laundering Steering Committee (the “AMLSC”) overseeing implementation. Priority actions include the establishment of a dedicated subgroup on TF and PF, and enhanced information-sharing arrangements.

2. Risk Assessment and Understanding

Increase collaboration across State agencies and civil society to identify emerging risks and improve understanding of criminal methods. This includes enhanced data collection from suspicious transaction reports, investigations and asset seizures. The DoF will examine the feasibility of requiring entities with reporting obligations to register with the Financial Intelligence Unit (the “FIU”) Ireland. The Central Bank of Ireland (the “CBI”) is expected to strengthen data collection on ML/TF, sanctions evasion risks and AML/CFT controls through its Risk Evaluation Questionnaire, while also analysing sectors, products and cross-border financial flows to identify vulnerabilities and areas most exposed to fraud and other offences.

3. Regulatory Framework (including Preventative Measures)

Ensure Ireland’s legal, regulatory and operational framework remains coherent and fit for purpose. Key actions include:

• EU AML Framework: transposition of the 6th Anti-Money Laundering Directive (AMLD6) into Irish law, assessing the impact on designated non-financial businesses and professionals, and preparing supervisors and FIU Ireland for cooperation with the new EU Anti-Money Laundering Authority (“AMLA”).
• Beneficial ownership: greater transparency, expanded beneficial ownership information, including plans to introduce mandatory disclosures of ultimate beneficial owners of Limited Partnerships. A single access point for real estate ownership information is to be established by July 2029.
• Crypto-Assets: further legislation is being introduced to implement EU AML/CFT requirements for crypto-asset transfers, in line with the FATF ‘Travel Rule’.
• Section 110 SPEs: the DoF will (a) introduce legislation to enable Revenue to publish a list of Special Purpose Entities (“SPEs”) that benefit from the section 110 regime under the Taxes Consolidation Act 1997 and (b) seek to implement a requirement for those entities to obtain a Legal Entity Identifier.
• Changing Financial Landscape: financial firms must ensure AML/CFT controls keep pace with new technologies. The CBI should continue to use its regulatory and supervisory powers to ensure that ML/TF and financial sanctions evasion risks are properly managed, including by enhancing its understanding of technologies such as Artificial Intelligence (AI), providing guidance to firms on governance and risk management, and increasing the use of technology in supervision and oversight.
• Gambling Sector: an industry standard for crypto-related sources of funds will be introduced. Gambling service providers will be required to operate a closed-loop payment system.
• Sanctions: the DoF plans to introduce a mechanism for prompt implementation of UN Security Council Sanctions and a standard process for national competent authorities to propose sanctions designations to the EU and the UN.

4. Capacity Building and Outreach

Key actions include targeted guidance from the Charities Regulator for organisations exposed to higher TF risks, annual reviews of risk-based supervisory approaches and the establishment of registers of Trust or Company Service Providers (TCSPs) by designated accountancy bodies, with consideration of a single national register. The CBI should provide firms with regular feedback on ML/TF risks, with firms incorporating this information into their risk management processes and AML/CFT controls.

5. International Cooperation

Ireland will continue to support international efforts to prevent and disrupt financial crime, including engagement with AMLA and FATF processes.

Key takeaways

The National Strategy underscores Ireland’s focus on having best-in-class systems to support AML/CFT/CPF efforts being made by the private sector businesses that engage directly with customers. While much of the strategy reflects the implementation of the EU’s most recent AML/CFT package and the consolidation of existing practices, there are some additional points of detail (such as transparency requirements for Limited Partnerships, section 110 SPEs, and the additional obligations for gambling service providers) that should be kept under close review.

How can McCann FitzGerald LLP help?

McCann FitzGerald LLP is a premier law firm in Ireland with deep expertise in relation to financial services regulation. If you would like to discuss further or require any specific financial services regulatory advice, including in relation to your AML, CFT or CPF requirements, please contact us.