Illustrative firm examples
Ireland country research brief
Research dated 2026-10-10 · Reviewed 2026-10-10
Version da68638e8325
da68638e8325e1c9aa1092f091a4b89fb0c6d23182816ccebec97c223920a254Scope: Illustrative firm examples. The selector is not an authorisation or legal-applicability determination. Source-check observations concern retrieval/access only and do not establish legal currentness; the research date is the content date boundary. Source health: review-required, checked 2026-10-12T06:10:06.110Z.
Framework and selected requirements
National framework and supervisory roles
The Law Reform Commission (LRC) revision of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 is dated 1 August 2025, not Ireland's full anti-money laundering and countering the financing of terrorism (AML/CFT) framework. The Central Bank of Ireland (CBI) supervises within its statutory remit; FIU Ireland is the financial intelligence unit (FIU) of An Garda Siochana. Other designated persons and supervisors have distinct roles: establish actual activity and statutory scope before assigning a duty or supervisor. CBI's listed 2021 financial-sector guidelines are non-binding, not proof of alignment with later law.
Retained-edition boundary
Retained legislation edition; current legal effect unverified. The LRC warns that later changes were not implemented as of 17 September 2026 and some amendments may await commencement. These reviewed 1 August 2025 examples are not confirmed current obligations, legal advice or firm applicability/authorisation/compliance approval.
Examples are activity- and trigger-specific
Section 30A addresses a designated person's business risk assessment. Section 33 has distinct relationship, occasional-transaction, suspicion, identity-doubt and other customer due diligence (CDD) triggers. Its delayed-verification conditions, pre-verification account rule, event-specific beneficiary provisions and legal-position/representation exception are not interchangeable. Section 109F is a conditional CBI power for qualifying non-branch cross-border providers. The two examples retain their actors, triggers and limits; bank, payments or crypto profiles alone establish none.
Risk and sanctions context
National threat is context, not a customer rating
The third Irish National Risk Assessment (NRA), published 18 June 2026, assesses money laundering (ML), terrorist financing (TF) and proliferation financing (PF) separately. It rates overall ML threat moderate, with drugs and fraud the leading sources, followed by theft/burglary, illicit trade/smuggling, trafficking/exploitation and tax crime. It rates TF and PF threats low; sanctions evasion is also rated low but warrants vigilance. Its executive summary rates ML risk very significant for traditional and digital banks, crypto-assets, e-money institutions and money-remittance payment institutions; very significant TF risk is identified for traditional/digital banks, crypto-assets and remittance payment institutions. The sector chapter differentiates e-money TF as significant and other non-remittance payment institutions as moderate for ML and TF. These are national assessment judgments, not a firm/customer score or automatic enhanced due diligence rule.
Translate exposure into a firm's own evidence
The NRA describes remittance exposure from rapid cross-border movement, cash, sector reach and agent/distributor controls; retail-bank exposure includes remote channels, money mules and transparency of virtual international bank account numbers (IBANs); crypto exposure includes rapid cross-border value movement, chain-hopping, privacy-enhancing techniques and decentralised finance (DeFi). Use relevant factors in the firm's own risk process where applicable, test actual products, channels, customer and geographic exposure, and document why controls are proportionate. The NRA does not itself require rejecting a customer, restricting a product or treating every firm in a sector as high risk. The associated 2026 action plan is planning context; listed actions are not proof of completion or firm-level requirements.
Sanctions require the applicable measure and nexus
The retained official sanctions page names the Department of Foreign Affairs, the Department of Enterprise, Trade and Employment, and the Central Bank of Ireland as competent authorities for distinct functions. EU regulations apply directly; Irish instruments provide domestic offences and penalties. The Department of Foreign Affairs coordinates international sanctions matters; the Central Bank of Ireland administers financial sanctions. Confirm other functions from the applicable measure. For a real party, asset or payment, identify the measure and test its actor/territorial scope, prohibited conduct, ownership/control, licence or derogation and reporting route. An Irish profile, euro payment or foreign counterparty alone does not establish UK, US or another regime's nexus. No live list, designation, ownership chain, transaction or licence was checked.
Selected firm implications
Meaning: Retained 1 August 2025 edition; current legal effect unverified. ML means money laundering; TF means terrorist financing. Section 30A sets a business-wide assessment using customer, product/service, geography, transaction and channel factors and relevant authority material, not a fixed score or interval. Later changes, commencement and designated-person status remain unverified.
Conditions: Actor: designated person, not every bank, payment or crypto firm. Verify current section 25 scope and activity.
Exceptions: Documentation exception only on the stated notified competent-authority decision; assessment remains. No wider exemption inferred.
Suggested action: If an in-scope designated person, document business ML/TF risk using the listed factors and relevant authority material; update under section 54 arrangements, obtain senior-management approval and provide records on competent-authority request.
National Legislation / Legislation / Retained legislation edition; current legal effect unverified · Section 30AMeaning: Retained 1 August 2025 edition; current legal effect unverified. CBI: Central Bank of Ireland. AML/CFT: anti-money laundering and countering the financing of terrorism. Section 109F allows the CBI to require an Irish central contact point for qualifying e-money issuers, payment service providers (PSPs) or crypto-asset service providers (CASPs) headquartered in another Member State and exercising establishment rights other than as a branch. No provider status or CBI requirement is inferred.
Conditions: Provider and cross-border criteria must all apply, and the CBI must require appointment. Check EU definitions and entity decisions.
Exceptions: No automatic payment/crypto duty: the non-branch condition excludes branch establishment. A profile establishes no crypto-asset registration or authorisation.
Suggested action: Only if the CBI requires it, the qualifying Irish contact point must ensure the provider's AML/CFT compliance and give requested information/records for supervision.
National Legislation / Legislation / Retained legislation edition; current legal effect unverified · Section 109FNotices and limitations
- Illustrative bank, payments and crypto examples, not an assessed firm profile.
- Product/customer exposure alone is not statutory applicability. This is not a licensing guide.
- Local entity / domestic activity selected.
- 2 representative dated legislation examples; see the full register for other duties.
- Legislation from a retained reviewed edition; later amendments, commencement and current legal effect are not verified. These are dated examples, not confirmed current obligations.
- Source observations are unavailable, stale, failed or review-required. This dated brief does not confirm today's legal position.
- Selected dated provisions only; not full-country coverage or verified current law/scope.
Evidence sources
Original source documents are not reproduced in this brief. Retained originals are private research evidence; use the official-source links.
- Official Legislation Original · Law Reform Commission · Administrative revision updated 1 August 2025; later changes/commencement and current legal effect unverified · Sections 30A, 33 and 109F; full original retained privately
- Official National Risk Assessment Original · Department of Finance and Department of Justice, Home Affairs and Migration · Third national ML/TF/PF assessment, published 18 June 2026; complete 306-page PDF · Executive summary pp. 12-14; ML threat pp. 43-46; sanctions pp. 82-91; banking pp. 121-133; crypto pp. 151-162; payment/e-money pp. 163-180
- Official Government Action Plan · Department of Finance (AML Policy Unit) · 2026 implementation plan; complete official PDF retained · Policy-planning context only; listed actions do not evidence completion or individual-firm compliance
- Official Publication Index · Department of Finance · Official publication index updated 15 July 2026; confirms linked 2026 NRA and action plan · Publication/source identity only; not legal-currentness evidence
- Official Supervisory Publication Page · Central Bank of Ireland · Official page re-opened 10 Oct 2026; lists 2026 NRA and 2021 CBI guidance · Publication listing; not substantive current-law confirmation
- Official Supervisory Information Page · Central Bank of Ireland · Retained official page, 20 Sep 2026; not rechecked in full 10 Oct · CBI AML/CFT remit context; not current statutory text
- Official Supervisory Information Page · Central Bank of Ireland · Official page retrieved 10 Oct 2026; availability only · CBI supervision and legacy virtual asset service provider scope; not crypto-asset authorisation status
- Official Sanctions Authority Page · Department of Foreign Affairs and Trade · Official page last updated 12 Apr 2025 · Competent-authority roles; not live designation data
- Official Supervisory Sanctions Page · Central Bank of Ireland · Official page retained 21 Sep 2026; retrieval only · CBI financial-sanctions context; not a consolidated measure or live list
CJA 2010, LRC revision 1 Aug 2025
Administrative revision updated 1 August 2025; later changes/commencement and current legal effect unverified · Sections 30A, 33 and 109F; full original retained privately
Source record
Retrieved 2026-09-27T00:00:00Z. SHA-256: c4a369eeb4702b672e55c9e30d43a17db0a63a8689b3d4560c9191e4894de642
Source retrieval check
observed · Checked 2026-10-12T06:10:00.491Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Ireland NRA 2026
Third national ML/TF/PF assessment, published 18 June 2026; complete 306-page PDF · Executive summary pp. 12-14; ML threat pp. 43-46; sanctions pp. 82-91; banking pp. 121-133; crypto pp. 151-162; payment/e-money pp. 163-180
Source record
Retrieved 2026-10-06T00:00:00Z. SHA-256: a23c8be243f1f41e9add0f1bd0380c0d7b4b93961a47b28cff12f9a0ab14888e
Source retrieval check
observed · Checked 2026-10-12T06:10:02.283Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Ireland NRA priority action plan 2026
2026 implementation plan; complete official PDF retained · Policy-planning context only; listed actions do not evidence completion or individual-firm compliance
Source record
Retrieved 2026-10-06T00:00:00Z. SHA-256: 60fc65667dd9a7f35cb68b07030119e4d66b7b329102357a46e930041073e40e
Source retrieval check
observed · Checked 2026-10-12T06:10:02.728Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Department of Finance NRA index, updated 15 Jul 2026
Official publication index updated 15 July 2026; confirms linked 2026 NRA and action plan · Publication/source identity only; not legal-currentness evidence
Source record
Retrieved 2026-09-21T00:00:00Z. SHA-256: cc8a44eecebe9c7f902df5a00ac0b8eb762436e0f68d11dd01cfe605435b1f2d
Source retrieval check
failed · Checked 2026-10-12T06:10:03.113Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
CBI risk and guidance page, checked 10 Oct 2026
Official page re-opened 10 Oct 2026; lists 2026 NRA and 2021 CBI guidance · Publication listing; not substantive current-law confirmation
Source record
Retrieved 2026-09-27T00:00:00Z. SHA-256: a6825b829d687613457bd3e952066d7ac828bb285082d9b0de5987d2ca288b5e
Source retrieval check
review-required · Checked 2026-10-12T06:10:03.393Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
CBI AML/CFT remit page, retained 20 Sep 2026
Retained official page, 20 Sep 2026; not rechecked in full 10 Oct · CBI AML/CFT remit context; not current statutory text
Source record
Retrieved 2026-09-20T00:00:00Z. SHA-256: 9f20797c096cc9a7fc3d392895d54d26cf85175bcc977c1932a49ca0de8b757c
Source retrieval check
review-required · Checked 2026-10-12T06:10:04.216Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
CBI virtual asset service provider page, retrieved 10 Oct 2026
Official page retrieved 10 Oct 2026; availability only · CBI supervision and legacy virtual asset service provider scope; not crypto-asset authorisation status
Source record
Retrieved 2026-10-10T00:00:00Z. SHA-256: 662d25668104c18ac042cab82d8692f929579ae54ef8db9006433771974c5ac1
Source retrieval check
observed · Checked 2026-10-12T06:10:05.094Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Ireland sanctions competent-authority page, updated 12 Apr 2025
Official page last updated 12 Apr 2025 · Competent-authority roles; not live designation data
Source record
Retrieved 2026-09-21T00:00:00Z. SHA-256: 121ce0ab894fcd3474cf0fb032f85805c2e75aeef5afc8775d383031b595114e
Source retrieval check
failed · Checked 2026-10-12T06:10:05.847Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
CBI financial sanctions FAQ, retained 21 Sep 2026
Official page retained 21 Sep 2026; retrieval only · CBI financial-sanctions context; not a consolidated measure or live list
Source record
Retrieved 2026-09-21T00:00:00Z. SHA-256: a1800fb7bdf9662e4641253b8d30f27d57fb3864fcf699173c08da0ba0e1f78f
Source retrieval check
review-required · Checked 2026-10-12T06:10:06.110Z
A retrieval check is an access observation only; it does not establish legal currentness. Research content date boundary: 2026-10-10.
This brief relies on the identified official source edition. Open it using the official-source control.
Retail bank
Meaning
Retained 1 August 2025 edition; current legal effect unverified. ML means money laundering; TF means terrorist financing. Section 30A sets a business-wide assessment using customer, product/service, geography, transaction and channel factors and relevant authority material, not a fixed score or interval. Later changes, commencement and designated-person status remain unverified.
Full public provision explanation
This provision sets a business-wide risk-assessment duty for designated persons. It specifies minimum risk factors and information sources, requires documentation subject to a notified competent-authority exception, requires updates under the person’s section 54 arrangements and senior-management approval, and allows the competent authority to request records. The statutory perimeter is the Act’s “designated person” definition, not every firm by default.
Suggested action
If an in-scope designated person, document business ML/TF risk using the listed factors and relevant authority material; update under section 54 arrangements, obtain senior-management approval and provide records on competent-authority request.
Conditions
Actor: designated person, not every bank, payment or crypto firm. Verify current section 25 scope and activity.
Exceptions
Documentation exception only on the stated notified competent-authority decision; assessment remains. No wider exemption inferred.
Payments and e-money
Meaning
Retained 1 August 2025 edition; current legal effect unverified. CBI: Central Bank of Ireland. AML/CFT: anti-money laundering and countering the financing of terrorism. Section 109F allows the CBI to require an Irish central contact point for qualifying e-money issuers, payment service providers (PSPs) or crypto-asset service providers (CASPs) headquartered in another Member State and exercising establishment rights other than as a branch. No provider status or CBI requirement is inferred.
Full public provision explanation
The Central Bank may require a qualifying cross-border electronic-money issuer, payment-service provider or crypto-asset service provider with a head office in another Member State and operating under establishment rights in a form other than a branch to appoint a State central contact point. If required, that point must ensure the entity's AML/CFT compliance and facilitate supervision by providing requested records/information.
Suggested action
Only if the CBI requires it, the qualifying Irish contact point must ensure the provider's AML/CFT compliance and give requested information/records for supervision.
Conditions
Provider and cross-border criteria must all apply, and the CBI must require appointment. Check EU definitions and entity decisions.
- Duty exists only if the Central Bank requires appointment; precise entity definitions incorporate EU law, including Article 45(9) terminology as amended by Regulation (EU) 2023/1113.
Exceptions
No automatic payment/crypto duty: the non-branch condition excludes branch establishment. A profile establishes no crypto-asset registration or authorisation.
- Conditional supervisory requirement, not automatic for all payment/crypto firms; EU definitions and current Central Bank determinations unverified.