RegSol Blog

AML 5th Directive: Update

January 2020

We expect 2020 will bring a host of interesting new developments and much needed clarity around the outcome of Brexit as well as the advent of still more regulatory change, including the expected transposition in full of the 5th EU AML Directive. 

As the European Union (Withdrawal Agreement) Bill 2019-20 weaved its way through the second reading of the UK’s House of Lords on the 13th of January, the UK Parliament had already implemented the European Union’s 5th AML Directive on time on the 10th. 

Ireland, on the other hand, had not and the 10th of January passed without any indication of when draft legislation will be available. AMLD5 introduces a number of key reforms including the expansion of the definition of obliged entities (designated persons in Ireland) to cover virtual currency exchange platforms and custodian wallet providers, art dealers, letting agents and tax advisors within the scope of the regime. 

This does not mean that Irish companies subject to the AML/CTF regime should remain complacent as it remains to be seen what is included in amending legislation. Firms likely to be brought in scope need to ensure they are performing gap-analyses and undertaking implementation projects to address the new requirements. 

If you’d like assistance in understanding your obligations under the 5th AML Directive, please do not hesitate to contact us at  

By Judy de Castro - Regulatory Consultant