Ireland - New AML Whistleblowing Requirements

New regulations have been introduced which require firms which are in-scope of Irish anti-money laundering legislation to introduce internal whistleblowing procedures regarding breaches of anti-money laundering legislation which are proportionate to the nature and size of their business.

The European Union (Money Laundering and Terrorist Financing) Regulations 2019 (the "Regulations") amend the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the "2010 Act") and require 'designated persons' – including regulated entities such as credit institutions, investment firms, payment and e-money institutions, investment funds and fund management companies and also 'Schedule 2' registered firms - to implement appropriate procedures for their employees, or persons in a comparable position, to report a contravention of the 2010 Act internally through a specific, independent and anonymous channel.

This client advisory addresses some of the factors which firms should consider when meeting these new obligations imposed by the Regulations.


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