AMLCU Annual Report 2025

Ireland’s AMLCU Annual Report 2024: Strengthening Oversight and Expanding Enforcement

The Anti-Money Laundering Compliance Unit (AMLCU) has published its 2024 Annual Report, outlining key supervisory, investigative, and enforcement activities carried out under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. As a supervisory authority for designated non-financial businesses and professions (DNFBPs), the AMLCU plays a pivotal role in ensuring these entities are not exploited for money laundering or terrorist financing.

Expanding Supervision Across Sectors

In 2024, the AMLCU increased its regulatory footprint, conducting 749 inspections, up 14% from 2023. This included 419 High Value Goods Dealers (HVGDs), 163 Trust or Company Service Providers (TCSPs), 66 gambling service providers, and 81 accountants and tax advisers. Notably, the number of authorised TCSPs rose by 6% to 468, with 134 applications processed for new and renewed authorisations. Additionally, 7 Private Members’ Clubs and 13 notaries underwent inspections.

Compliance and Enforcement Actions

Following inspections, compliance levels varied across sectors, with HVGDs and TCSPs achieving relatively higher adherence, while gambling service providers and PMCs faced challenges. The AMLCU issued 49 legal directions under Sections 68 and 71 of the Act, requiring entities to take corrective actions. Furthermore, 59 Competent Authority Reports (CARs) were filed with FIU Ireland and Revenue, reflecting instances of suspected money laundering or terrorist financing uncovered during inspections.

Responding to Geopolitical Risks

The Russian invasion of Ukraine and subsequent EU sanctions packages had implications for AMLCU-supervised entities, particularly jewellers, bullion dealers, and TCSPs. While the AMLCU does not enforce sanctions, it worked closely with the Cross-Departmental International Sanctions Committee (CDISC) to guide entities on compliance and directed them to relevant resources.

Advancing Regulatory Tools

A major development in 2024 was preparation for the implementation of the EU’s 6th Anti-Money Laundering Directive (EU 2024/1640). This includes expanding the AMLCU’s enforcement toolkit to introduce administrative fines through Fixed Charge Penalty Notices, enhancing Ireland’s ability to respond swiftly to non-compliance.

Promoting Awareness and Guidance

On 28 March 2024, the AMLCU released its Anti-Money Laundering & Countering the Financing of Terrorism Guidelines, providing detailed instructions for designated persons on meeting their obligations. Outreach activities included ‘streetscape’ events in cities like Donegal, Limerick, Athlone, and Dublin, combining on-site inspections with educational seminars. The AMLCU also strengthened collaboration with domestic regulators, representative bodies, and international counterparts, including officials from France and Delaware (USA), and contributed to Ireland’s participation in FATF initiatives.

Looking Ahead

The 2024 report underscores the AMLCU’s growing capacity to oversee an increasingly diverse regulated population while adapting to evolving threats. With the upcoming administrative sanctions regime and ongoing engagement with national and international stakeholders, Ireland continues to enhance its anti-money laundering and counter-terrorist financing (AML/CFT) framework.