21 August 2026
On 13 August 2026 the Government launched the first national AML, Countering the Financing of Terrorism (“CFT”) and Countering Proliferation Financing (“CPF”) Strategy (“the Strategy”) which forms part of Ireland’s implementation of the EU’s AML Legislative package.
This proposed Strategy covers the period 2026-2030 and takes into account the National Risk Assessment (“NRA”) published in 2026, together with extensive consultation across both private and public sector stakeholders. The NRA assessed the overall money laundering threat in Ireland as “moderate”, with terrorist financing and proliferation financing assessed as “low risk”, however, the NRA noted the importance of monitoring risks associated with digital platforms, crypto-assets, and sanctions evasion. These findings provide the context for the goals and actions set out in the Strategy.
The Strategy identifies five strategic goals, which are intended to address matters identified through the NRA, national performance assessments, and recent reviews of the Irish AML/CFT/CPF framework. These goals are:
A key action identified in the Strategy is the implementation of the European Union's "6AMLD".
6AMLD transposition will be staggered over the next year, with some of the Directive in place since last July (2026), with the bulk of it due to be transposed by July 2027. There is a ‘final extension’ date of 2029 for certain real estate registry data.
It is also planned that the Department of Finance (“the Department”) will engage with stakeholders regarding the establishment of a single point of access to real estate information, as required under Article 18 of 6AMLD
The Strategy has looked at the broader financial landscape and identified matters for concern and proffered recommendations addressing them.
The Strategy has identified the Gambling Sector as an area requiring enhanced measures and has suggested that:
With an eye on the technological developments and innovation in financial services, the Strategy recommends that the Central Bank should consider:
It is envisaged that there would be greater cooperation between various enforcement entities including An Garda Síochána, the Revenue Commissioners, the Central Bank, FIU Ireland, the Criminal Assets Bureau, and any other regulatory entities that may need to be involved.
The Strategy also offers a proposal to develop a framework to support the parallel investigation of money laundering offences and associated tax or excise offences.
This collaboration between various regulatory bodies would hopefully streamline cooperation between the domestic enforcement offices.
It is proposed that legislation enabling the Revenue Commissioners to publish a list of Special Purpose Entities (“SPE”) availing of the Section 110 regime of the Taxes Consolidated Act 1997. This regime provides for the taxation of certain ‘qualifying’ special purpose companies.
The Strategy also refers to the introduction of a requirement for Legal Entity Identifiers on entities availing of said regime.
It is further proposed under the strategy that:
The Strategy does not in itself introduce new obligations, rather it identifies legislative, regulatory, and operational measures for implementation by Government departments, regulatory authorities, and enforcement bodies. These measures, if implemented, are intended to strengthen Ireland’s AML/CFT/CPF regime and support implementation of the overall EU AML legislative package.
The Strategy sets out the government’s proposed AML/CFT/CPF framework for the next 4 years and should be looked at in conjunction with the NRA and Priority Action plan. It seeks to strengthen the framework through a whole- government approach, therefore streamlining matters. The implementation of these measures is expected to involve a number of legislative, regulatory, and operational developments relevant to regulated entities, so for now it is a case of ‘wait and see’ as to how, and if, the Strategy will impact various sectors.
The Financial Services Regulation team within KPMG Law LLP can assist regulated entities in understanding and responding to their regulatory and supervisory priorities.
We advise across the full lifecycle of regulatory engagement, including governance and accountability frameworks, operation and financial resilience, consumer and investor protection, and the implementation of evolving EU and domestic regulatory requirements.
