AMLR Readiness Hub

The cornerstone of the package. Directly applicable from 10 July 2027 — no national transposition required. Creates a single EU rulebook for CDD, beneficial ownership transparency and risk assessment.

• Harmonised mandatory CDD data fields (defined in RTS Art 28) replace all domestic templates including CBI guidance
• New mandatory EDD category for individuals with €50m+ in investable assets (excluding primary residence)
• UBO threshold set at 25% — reducible to 15% for higher-risk entity categories identified by member states
• EU-wide €10,000 cash transaction limit introduced for the first time
• Prohibition on anonymous cryptoasset wallets and anonymity-enhancing coins from Day 1
• New PEP definition — expanded family and close associate scope

Key point for Irish entities: the AMLR replaces the Criminal Justice (Money Laundering and Terrorist Financing) Acts framework. CBI will continue as national supervisor for non-AMLA entities.

The Anti-Money Laundering Authority, headquartered in Frankfurt, represents a paradigm shift in EU AML supervision. It assumes direct supervision of up to 40 cross-border credit and financial institutions.

• Direct supervision of selected "significant" cross-border entities from 2028
• Eligible entity list published January 2027; formal selection announced July 2027
• Coordination and oversight of national supervisors including CBI
• Binding regulatory and implementing technical standards (RTS/ITS)
• Derville Rowland, former CBI Deputy Governor, appointed to AMLA's Executive Board (May 2025)
• Centralised database of AML/CFT supervisory information across EU member states

The Sixth AML Directive addresses governance, national supervisory frameworks and areas requiring member state flexibility. Transposition must be complete by 10 July 2027.

• Two prescribed roles for all obliged entities: Compliance Director (board-level) and Compliance Manager (operational)
• Compliance Manager has whistleblower-style protections; dismissal must be notified to supervisor
• Fit-and-proper requirements for senior management extended across all obliged entity types
• Harmonised sanction grading (RTS Art 53 AMLD6) — four severity categories
• Forced governance change available as a supervisory tool for category 3–4 infringements

Already in force. Extends information-accompanying-funds obligations to crypto-asset transfers, closing a critical gap by applying the same transparency requirements as traditional finance to virtual assets.

• Travel rule now applies to all crypto-asset transfers — no de minimis threshold
• CASPs must transmit originator and beneficiary information with all transfers
• Self-hosted wallet transactions require risk identification and documented mitigation by the CASP
• CARF/DAC8 crypto-asset tax reporting also active — separate registration and reporting obligations with Revenue