Useful resources

Page updated 1 May 2024

Ireland

National risk assessment :In 2019 the Department of Finance and the Department of Justice and Equality published Ireland's first Money Laundering and Terrorist Financing (ML/TF) National Risk Assessment (NRA). It is an assessment of the ML/TF threats in Ireland and the vulnerabilities of certain sectors to being used for ML/TF as a result of the products and/or services they offer, their customer base, the countries in which they operate and the delivery/distributions channels they utilise.

In the report the accountancy services sector is given a medium-high final risk rating. The report states that the specialist nature of the knowledge and services provided by the accountancy service providers makes them vulnerable to being sought out and exploited by those who seek to launder the proceeds of crime or evade tax. The report also recognises that the risks are mitigated by the supervision of accountancy regulatory bodies. However it notes that this mitigating factor is not present for all accountancy services providers and therefore the sectoral risk assessment is judged to be Medium-High on the basis of the nature of the services provided, the scale of the sector and the low level of STR reporting from the sector.

United Kingdom

HM Treasury published its national risk assessment of money laundering and terrorist financing in 2020. In this report the risk of money laundering through Accountancy Service Providers (ASPs) is  rated high . The report states that accountancy services remain attractive to criminals due to the ability to use them to help their funds gain legitimacy and respectability, as implied by ASPs’ professionally qualified status. Those providing accountancy services remain at risk of being exploited or abused by criminals, especially if ASPs become complacent in their regulatory obligations under legislation , or willingly facilitate money laundering. The accountancy services considered most at risk of exploitation continue to be company formation and termination, mainstream accounting and payroll. The report also states that HM Treasury continues to judge that accountancy services are not attractive for terrorist financing, and there remains no evidence of these services being abused by terrorists. There are a couple of useful AML case studies detailed in this report.

Please also  see here for the first UK national risk assessment of proliferation financing  published in September 2021 by HM Treasury. Proliferation Financing (PF) is financing for the malicious use of chemical, biological, radiological and nuclear materials and weapons. The publication notes that awareness of PF risk in the Designated Non-Financial Businesses and Professions (DNFBPs) sector is, in general, low in most countries, which could represent a particular risk to the UK, notably in relation to trust and company service providers given the ease of establishing companies in the UK.

National Crime Agency :The National Crime Agency (NCA) is a non-ministerial government department, the role of which is to protect the public from the most serious threats resulting from organised crime. Click the following link for NCA money laundering and illicit finance pages.

 It  publishes an annual plan which sets out how it will meet its strategic and operational priorities in the year ahead. Click the link for the latest Annual Plan 2023-2024.

The NCA also publishes an annual report summarising its performance against that plan. Click the link for the Annual Report 2022-2023.

The NCA publishes a bulletin called SARs in Action a number of times a year. You can access it by going to the publications page and searching in the description box by title. The SARs in action publication deals with topical issues sometimes including SARs case studies. 

See also the reporting requirements page for further information on the NCA.

European Union

Click here for the European Union page.

International

Financial Action Task Force

The Financial Action Task Force (FATF) is an independent intergovernmental organisation established by the G-7 in 1989 in response to mounting concern over money laundering .The United Kingdom is a member since 1990. Ireland joined in 1991. FATF leads the international fight against money laundering and terrorist financing, setting international standards and promoting the effective implementation of legal, regulatory and operational measures for combatting money laundering, terrorist financing and other related threats to the integrity of the international financial system. See for example its publication in March 2021 (with EGMONT group) of Trade-Based Money Laundering Risk Indicators which  will help public and private sector identify possible trade-based money laundering.

The FATF has developed a series of recommendations that are recognised as the international standard for combating money laundering and the financing of terrorism and proliferation of weapons of mass destruction. The recommendations are regularly revised to ensure that they remain up to date and relevant, and they are intended to be of universal application. The Irish Minister for Finance at the Select Committee on Justice on 19 Nov 2020 made reference to the use of FATF recommendations in drafting Irish legislation relating to the creation of a  registration and supervision regime for AML purposes of Virtual Asset Service Providers. This is now contained in the Criminal Justice (Money Laundering and Terrorist Financing ) (Amendment ) Act 2021.

The FATF monitors the progress of its members and the most recent Mutual Evaluation Report (MER) on Ireland, was published in September 2017. An executive summary of the report is also available. In February 2022 FATF  issued its “Follow up Report -Ireland 2022” on Anti-money laundering and counter-terrorist financing measures in Ireland. Since its 2017 FATF assessment and 2019 follow up, Ireland has taken a number of actions to strengthen its framework. To reflect its progress, the FATF has now re-rated Ireland on DNFBPs (Designated Non-Financial Businesses and Professions): Customer due diligence, from partially compliant, to largely compliant. Also, as Ireland has met many of the new requirements introduced for Virtual Asset Service Providers with only minor deficiencies remaining it has retained its rating as remaining largely compliant in this area. You can read the full report here.

The  2018 UK Assessment can be downloaded here.

FATF provides an overview of planned assessments .In the 5th Round of FATF Mutual Evaluations Ireland is listed for a possible onsite period in April 2028 and possible plenary discussion in October 2028.The UK is listed for a possible onsite period in August  2027 and possible plenary discussion in February 2028.

FATF publishes annual reports. Click the link to its Annual Report for 2022-2023

The Organisation for Economic Co-operation and Development

The Organisation for Economic Co-operation and Development (OECD) is an international policy shaping organisation . It works with governments, policy makers and citizens, to establish international standards and solutions to a range of social, economic and environmental challenges. Ireland and the United Kingdom are members.

Click the link for the OECD report which evaluates Ireland’s Criminal Justice (Corruption Offences) Act 2018, which came into force in July 2018. Read the OECD UK report detailing the United Kingdom's achievements and challenges in respect to implementation and enforcement of the OECD Anti-Bribery Convention.

The OECD has also produced the useful publication Money Laundering and Terrorist Financing Awareness Handbook for Tax Examiners and Tax Auditors which is a practical tool to assist tax authorities in identifying money laundering during the course of normal tax audits. The handbook published in 2009 and updated in 2019 includes updated money laundering indicators and new material to increase detection and reporting of terrorist financing.

These pages are provided as resources and information only and nothing in these pages purports to provide professional or legal advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.