AML and CFT

The fight against money laundering and terrorist financing is entering a transformative period across Europe, and Irish financial institutions are at the centre of that change.

A changing landscape for financial crime supervision 

The Central Bank of Ireland has significantly intensified its focus on financial crime risk, reflecting both the growing sophistication of criminal networks and Ireland's position as a major international financial centre. Recent regulatory developments signal that firms should expect greater scrutiny, more data-driven supervision and higher expectations regarding governance and risk management.

One of the most important developments is the implementation of the EU's AML Package. Published in 2024, the package introduces a harmonised AML framework across the European Union and establishes the Anti-Money Laundering Authority (AMLA), which will commence direct supervision of selected high-risk institutions from January 2028. The new AML Regulation will apply directly across Member States from July 2027, fundamentally reshaping compliance expectations.

At a domestic level, the Central Bank has adopted a more integrated approach to financial crime supervision, bringing together AML, CFT, sanctions and fraud risk oversight. The regulator has also enhanced its risk-based supervisory model through more detailed sector-specific Risk Evaluation Questionnaires, enabling a deeper assessment of firms' money laundering, terrorist financing and proliferation financing risks.

Emerging risks are also driving regulatory attention. Crypto-asset services, payments innovation, fraud and AI-enabled criminal activity are increasingly prominent themes within the Central Bank's financial crime agenda. Firms are expected not only to comply with existing requirements but to proactively identify vulnerabilities and strengthen controls.

The organisations that thrive in this environment will be those that view AML and CFT as more than regulatory obligations. Effective financial crime frameworks protect reputation, support sustainable growth and reinforce stakeholder confidence.

As AMLA prepares to reshape supervision across Europe and the Central Bank continues to increase its focus on data-driven financial crime oversight, firms have a narrowing window to ensure their frameworks are ready for the next phase of regulatory scrutiny.

Now is the time for boards, MLROs, compliance leaders and senior management teams to challenge whether their AML/CFT operating model is genuinely risk-led, technology-enabled and capable of responding to increasingly sophisticated threats.

How Crowe can help

Our Risk Consulting team is working with regulated firms across the financial services sector to assess AML/CFT maturity, enhance governance and oversight arrangements, strengthen control frameworks and prepare for the implications of the new European AML regime. Those that invest now will not only reduce regulatory risk but will also build stronger, more trusted and more resilient businesses in the years ahead.

In a market where regulatory expectations continue to rise, the most successful organisations will be those that treat financial crime compliance not as a cost of doing business, but as a strategic enabler of growth, trust and long-term value.