Ireland update - Fifth Anti-Money Laundering Directive implementation – committee stage amendments on virtual asset service providers

In our September 2020 advisory, we commented on the publication of the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill 2020 (the “Bill”), which will amend the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the “CJA 2010”) to transpose elements of the Fifth Anti-Money Laundering Directive (“5AMLD”).

On 19 November 2020 an updated version of the Bill was published which includes the amendments of the Select Committee on Justice (the “Amended Bill”).1 Under the Amended Bill, the CJA 2010 will be updated to impose anti-money laundering and counter-financing of terrorism (“AML/CFT”) obligations on a wider range of virtual asset service providers (“VASPs”) than those which were captured under the Bill as initiated.

The Amended Bill will amend the CJA 2010 to meet latest international standards and go further than the 5AMLD requirements in this area.


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Niall Esler PartnerT +353 1 863 8517
Conor DalySenior AssociateT +353 1 470
Shane MartinOf CounselT +353 1 470
Bill LaffanAssociateT +353 1 863