Ireland Update – Publication of Draft Legislation Implementing Fifth Anti-Money Laundering Directive

A bill which will transpose the Fifth Anti Money Laundering Directive into Irish law has been published. The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill 2020 will effect a number of key changes to Irish AML/CFT law including:

  • the extension of scope of ‘designated persons’ to include additional categories of businesses such as virtual currency exchange providers;
  • new obligations on designated persons regarding checks of customers who are subject to beneficial ownership disclosure requirements and verification of identity of senior managing officials;
  • amendments to e-money instrument customer due diligence value thresholds;
  • prescribed actions for enhanced customer due diligence for customers in high-risk third countries; and
  • amendments to politically exposed person requirements.

It is expected that the Department of Finance will bring forward additional legislative amendments to establish a central register of beneficial ownership for express trusts, establish centralised national bank and payment account registers and to provide for a registration and fitness and probity regime for virtual currency exchange providers.


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