Ireland unveils AML plan with tougher crypto, travel rule measures

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Ireland has launched its first national anti-money laundering (AML) strategy, introducing new obligations for digital asset firms, requiring “enhanced checks” on transfers involving private crypto wallets, and stricter due diligence when dealing with overseas crypto-asset firms.

On August 13, Tánaiste (deputy prime minister, or deputy Taoiseach) and Finance Minister Simon Harris TD published the country’s first national anti-money laundering, countering financing of terrorism, and countering proliferation financing (AML/CFT/CPF) strategy, setting out a comprehensive plan to strengthen the government’s response to financial crime.

For digital asset firms, it provides for the extension of AML/CFT obligations to crypto-asset transfers, requiring information on the originator and beneficiary to accompany transfers, as well as requirements to promote greater transparency and traceability of crypto-asset transfers, enhance checks on transfers involving private crypto wallets, and impose stricter due diligence when dealing with overseas digital asset firms.

Under Ireland’s previous AML/CFT framework, digital asset firms were subject to obligations under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. However, the regulatory framework was largely built around traditional financial institutions and other “designated persons,” with crypto businesses subject to national AML requirements rather than a harmonized and bespoke European Union-wide regime—i.e., the bloc’s Markets in Crypto-Assets (MiCA) regulation.

The new strategy reflects the introduction of MiCA, which designated Crypto-Asset Service Providers (CASPs) as a new regulated entity subject to EU and national AML/CFT requirements. Notably, the Transfer of Funds Regulation (TFR) extends AML/CFT obligations to crypto-asset transfers and implements the Financial Action Task Force (FATF) ‘Travel Rule’, requiring information on the originator and beneficiary to accompany transfers.

As noted in the Irish government’s new strategy paper: “An industry standard will be established relating to the acceptance of crypto-related activities as a source of funds to ensure appropriate due diligence is performed and the legitimacy of the funds are verified.”

It adds that “this promotes greater transparency and traceability of transactions, helping to combat money laundering and terrorist financing across the EU.”

For CASPs, the strategy entails more explicit and comprehensive regulatory obligations, particularly regarding customer due diligence, transaction monitoring, and the collection and transmission of information in transfers. Firms will need systems capable of capturing and sharing required transaction data and demonstrating compliance to regulators.

“Criminal organizations are becoming increasingly sophisticated. They are exploiting new technologies, crypto-assets and complex international financial networks to conceal criminal profits,” Harris TD said. “Government must continue to stay ahead of those threats.”

For this reason, he said the strategy aims to underpin “the most significant strengthening of Ireland’s anti-money laundering framework in years,” while sending a clear message that Ireland will continue to take a robust approach to tackling organized crime and strengthening financial integrity.

Ireland crypto licenses

The landmark MiCAR framework came fully into force on December 30, 2024, and required CASPs operating in the EU to apply for a license and obtain authorization from the national competent authority (NCA), the designated regulatory body in an EU member state, where their operations are based.

Under a transitional regime, CASPs operating in the EU could continue operating while they apply for MiCA authorization for up to 18 months after the December 30 implementation date, or until their MiCA license is granted or refused, whichever is sooner. Meaning, firms that failed to apply for a license by July 1, 2026, or fail in their application, would have to cease operating across the 27-nation bloc immediately.

The European Securities and Markets Authority (ESMA), the EU authority responsible for enhancing investor protection, promoting orderly markets, and ensuring financial stability, recently updated its register of authorized CASPs, adding 12 new names to the list, including German cooperative banks Volksbank Raiff eisenbank Oberbayern Südost, VR Bank Schleswig-Holstein Mitte, and VR-Bank Landau-Mengkofen.

This was the fourth such update since the July 1 transitional deadline, bringing the total number of authorized CASPs to 321.

Ireland’s NCA, the Central Bank of Ireland (CBI), has contributed twelve names to this list—as of the current EMSA register—the most significant being Kraken, one of the world’s leading cryptocurrency exchanges.

Other notable names among the Irish cohort include Interactive Brokers, a major global electronic brokerage serving professional and retail investors, and StoneX, another substantial traditional financial services group.

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