New AML Guidance Issued for Accountancy Firms


The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 was amended in November 2018 by the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018, giving effect to certain provisions of the Fourth Money Laundering Directive.

Technical Release 01/2019, Anti Money Laundering Guidance, has been prepared to help accountancy firms to fulfil their obligations under the updated Irish legislation to prevent, recognise and report money laundering. The guidance will assist firms comply with the relevant legislation (including that related to counter terrorist financing) and professional requirements.

The new guidance replaces M42, AML Guidance. Firms are advised to review their current policies and procedures to ensure that they meet these requirements.

Key changes introduced by the amending Act include greater emphasis on identification of beneficial owners of businesses, a wider definition of politically exposed persons, a requirement to apply procedures based on an enhanced risk based approach to assess and respond to potential money laundering or terrorist financing, enhanced requirements relating to client identification, and the removal of an earlier duty to report in relation to conduct of business with parties connected with a high risk jurisdiction,  regardless of specific assessed risks arising from such business.