The EU’s anti-money laundering framework is becoming more consistent across Member States, putting greater emphasis on risk assessment, customer due diligence, beneficial ownership and ongoing monitoring.

Anti-money laundering compliance is moving towards a more harmonised EU framework. For Irish accountants, that makes robust customer due diligence, risk assessment and internal controls increasingly important.

The latest EU AML package introduces a new directly applicable Anti-Money Laundering Regulation (AMLR), a new Anti-Money Laundering Directive and the EU Anti-Money Laundering Authority (AMLA).

The timetable matters. The AMLR will generally apply from 10 July 2027, while Member States must transpose most of the new directive by the same date. Certain beneficial ownership provisions had an earlier July 2026 deadline.

For accounting practices, the practical message is straightforward: AML should be treated as an ongoing risk-management process rather than a one-off client onboarding exercise.

1. Customer due diligence remains central

Neil Rafter’s webinar placed Know Your Customer (KYC) and customer due diligence at the centre of effective AML compliance.

That starts with establishing who you are dealing with. Depending on the circumstances, firms need to understand the customer’s identity, beneficial ownership and the purpose and nature of the business relationship.

But due diligence does not finish once the client has been onboarded.

The webinar highlighted the importance of ongoing monitoring, including scrutiny of transactions and reassessing information when something no longer appears consistent.

That means firms should consider whether their existing procedures can answer practical questions such as:

• Do we know who ultimately owns or controls this entity?
• Do we understand the purpose of this business relationship?
• Have we considered whether the customer or beneficial owner is a politically exposed person?
• Are transactions consistent with what we know about the client?
• Do we have a process when existing identification information becomes doubtful?

The new AMLR will apply directly across EU Member States from July 2027, creating a more harmonised framework for these obligations.

2. Beneficial ownership needs proper verification

Beneficial ownership was another recurring theme throughout the webinar.

For accountants, identifying the person named on a document may not be enough. You need appropriate procedures for establishing who ultimately owns or controls the entity or arrangement.

Ireland already operates central beneficial ownership arrangements for companies and trusts. The new EU framework develops this area further, with some beneficial ownership provisions under the new directive requiring earlier transposition than the wider July 2027 deadline.

The practical issue is therefore not simply whether your practice collects beneficial ownership information. You should also consider how that information is verified, documented and reviewed.

3. Risk assessment should drive your AML procedures

A recurring message from the session was that AML compliance needs to be proportionate to risk.

Practices should have a clear risk-management framework rather than applying procedures without considering the circumstances of the client or transaction.

Higher-risk relationships may require additional attention. Relevant factors discussed during the webinar included politically exposed persons, suspicious transactions, beneficial ownership structures and dealings involving higher-risk jurisdictions.

The important point is not to make assumptions about risk based on informal impressions. Firms need documented processes capable of identifying and responding to the relevant risk factors.

4. AMLA adds a new layer of EU-level oversight

One of the biggest structural developments is the establishment of the Anti-Money Laundering Authority (AMLA).

AMLA was legally established in 2024 and began exercising its powers and responsibilities on 1 July 2025. Based in Frankfurt, it is developing the EU-wide supervisory system, supporting the single rulebook and coordinating the work of Financial Intelligence Units.

This does not mean every Irish accounting practice will suddenly be supervised directly from Frankfurt.

It does mean firms are operating within a system designed to make AML standards and supervision more consistent across the EU.

Ireland is also working on legislation needed to transpose the new directive into national law.

5. Policies are only useful when people follow them

Written AML procedures are not enough if staff do not understand them.

The webinar emphasised staff awareness and training alongside customer due diligence, reporting and monitoring. Firms need people to recognise when established procedures apply and what to do when something does not look right.

That makes AML training part of the control environment rather than simply an administrative requirement.

Practices should consider whether relevant staff understand their responsibilities around customer identification, beneficial ownership, risk assessment, suspicious activity and escalation.

Internal procedures should also be reviewed as requirements develop.

What should accounting practices do now?

The new EU framework does not mean every future obligation already applies today. The principal AMLR application date remains July 2027, and Ireland is continuing its national implementation work.

However, the direction is clear.

Accounting practices should review whether their current AML arrangements provide a reliable process for assessing client risk, establishing identity and beneficial ownership, conducting appropriate due diligence, monitoring relationships and escalating suspicious activity.

The key takeaway from Neil Rafter’s session was that AML compliance is becoming broader, more coordinated and more closely supervised.

For accountants handling client relationships and financial information, preparation starts with making sure the fundamentals already work.

FAQ: Anti-Money Laundering changes for Irish accountants

What is changing in EU anti-money laundering regulation?

The EU is moving towards a more harmonised anti-money laundering framework across Member States. The changes include a new Anti-Money Laundering Regulation (AMLR), a new Anti-Money Laundering Directive and the establishment of the EU Anti-Money Laundering Authority (AMLA).

For Irish accounting practices, this increases the importance of effective risk assessment, customer due diligence, beneficial ownership checks and ongoing monitoring.

When will the new EU AML rules apply?

The new Anti-Money Laundering Regulation will generally apply from 10 July 2027. Member States must also transpose most provisions of the new Anti-Money Laundering Directive by that date, although certain beneficial ownership provisions have an earlier timetable.

Irish firms should therefore distinguish between existing AML obligations and new requirements that are still being implemented.

What is AMLA?

AMLA is the European Union’s Anti-Money Laundering Authority. It forms part of the EU's new framework for combating money laundering and terrorist financing.

Its role includes supporting more consistent supervision across the EU, contributing to the development of the EU AML rulebook and coordinating Financial Intelligence Units.

This does not mean every Irish accounting practice will be directly supervised by AMLA.

What is customer due diligence?

Customer due diligence involves establishing and verifying who you are dealing with and understanding the nature of the business relationship.

Depending on the circumstances, this includes identifying customers and beneficial owners, understanding the purpose of the relationship and assessing relevant AML risks.

Due diligence should not be viewed solely as an onboarding exercise. Ongoing monitoring is also an important part of the process.

What is beneficial ownership, and why does it matter?

Beneficial ownership concerns the individuals who ultimately own or control an entity or arrangement.

For accounting practices, identifying the person named on a company document may therefore be insufficient. Appropriate procedures are needed to establish, verify and document the individuals who ultimately own or control the client.

Practices should also consider how beneficial ownership information is kept under review.

What does a risk-based approach to AML mean?

A risk-based approach means assessing the money-laundering risk associated with a client or business relationship and applying appropriate controls.

The webinar highlighted factors including politically exposed persons, beneficial ownership structures, suspicious transactions and connections with higher-risk jurisdictions.

The important point is that risk decisions should follow documented procedures rather than informal assumptions.

What is a politically exposed person?

A politically exposed person, or PEP, is someone whose position can create particular exposure to risks including bribery and corruption.

The webinar identified PEP checks as an important consideration when assessing customer risk. Firms should have procedures for identifying relevant cases and applying the appropriate level of due diligence.

[CHECK: verify current statutory definition and applicable Irish requirements before adding detailed PEP categories.]

Does AML due diligence stop once a client has been accepted?

No. The webinar emphasised ongoing monitoring as part of effective AML compliance.

Practices should consider whether transactions and activity remain consistent with what they know about the client and the business relationship. Changes in ownership, activity or other risk factors may also require information to be reviewed.

What should an accountant do if a transaction looks suspicious?

A firm should follow its established AML procedures for identifying, escalating and reporting suspicious activity.

Staff therefore need to understand both the warning signs and the firm's internal reporting process.

The webinar discussed suspicious activity reporting as part of the wider AML control framework. Specific legal reporting requirements should be checked against current Irish legislation and official guidance.

Why is AML training important for accounting firms?

AML policies only work when the people applying them understand their responsibilities.

Relevant staff need sufficient awareness to recognise risk indicators, carry out required checks and know when concerns should be escalated.

Training should therefore support the firm's wider AML controls rather than being treated as a standalone administrative exercise.

What should Irish accounting practices review now?

Practices can use the changing EU framework as an opportunity to review the fundamentals of their existing AML processes.

That includes considering whether the firm has reliable procedures for:

• assessing client risk;
• identifying and verifying customers and beneficial owners;
• carrying out appropriate customer due diligence;
• monitoring ongoing client relationships;
• identifying and escalating suspicious activity; and
• ensuring relevant staff understand their AML responsibilities.

The new EU framework does not mean every future requirement already applies. Firms should continue checking current Irish requirements as the EU measures are implemented nationally.

The contents of this article are meant as a guide only and are not a substitute for professional advice. The authors accept no responsibility for any action taken, or refrained from, as a result of the material contained in this document. Specific advice should be obtained before acting or refraining from acting, in connection with the matters dealt with in this article.