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sentinel. Carried Sentinel position for the payments context only (no original FIM illicit-finance analysis). Ireland's AML/CFT base instrument is the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended, CJA 2010), with the CBI as competent authority for credit/financial institutions including VASPs/CASPs. The EU AML package (adopted 30 May 2024) — AMLR, AMLD6, AMLA Regulation, recast Funds Transfer Regulation (FTR, in application since 30 December 2024) — applies; the directly-applicable AMLR binds Irish obliged entities (incl. payments firms) from 10 July 2027, AMLA (Frankfurt) began operations 1 July 2025. Ireland implemented the recast travel rule via S.I. 389/2025.
The forward shift is the EU AML package. Per the Sentinel feed, the directly-applicable AML Regulation (AMLR) applies in all member states from 10 July 2027 with no national opt-outs, largely replacing the CJA 2010 for payments and crypto firms; AMLA in Frankfurt commenced operations on 1 July 2025, and former CBI Deputy Governor Derville Rowland was appointed to AMLA's Executive Board in May 2025. The AMLR harmonisation and AMLA central supervision will reshape AML compliance for Irish payments firms, with an Irish presence on the AMLA board. Source: Sentinel (sentinel://kpmg.ie/aml-amla-readiness).
Outlook
The AML/CFT trajectory is escalating. The CJA 2010 base plus the S.I. 389/2025 travel rule are the current standing position, while the AMLR binding Irish obliged entities from 10 July 2027 and AMLA's central supervision from 1 July 2025 are the major forward changes. Because this module is Sentinel-fed, original illicit-finance analysis — including FATF mutual-evaluation depth and bank-versus-non-bank supervision detail — is out of World Payments scope and routed to FIM; the record here is provenance-limited to the payments context.
no periodic updates on record for this sub-brief
Sources and findings (9)
- T3sentinel://deloitte.ie/amlr-readiness
- T?FIM (sentinel.gi) per-JID baseline profile — Ireland — Ireland's AML/CFT regime rests on the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010-2021 (5AMLD-transposing), with the Central Bank of Ireland as lead AML/CFT supervisor for financial institutions and VASPs, the FIU embedded in the Garda National Economic Crime Bureau, and the CRO/RBO handling corporate and beneficial-ownership registration. As an EU member and international financial centre, Ireland will absorb the AMLR/AMLA package and MiCA in parallel.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: capacity-deficit
- T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: An Garda Síochána / National Crime Agency (joint operation) — Cross-border organised crime cash-laundering network
- T2FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: EU divergence
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence
- T2FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: Government of Ireland — Aughinish Alumina (Rusal-owned refinery, Co. Limerick)
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure