Transparency International (TI) Ireland has welcomed a number of significant commitments in the Government's 2026 National Risk Assessment on money laundering and action plan but has warned that the plan could go further to fully address Ireland's exposure to transnational illicit finance.
The National Risk Assessment on money laundering, terrorist financing and proliferation financing (NRA), and its accompanying Priority Action Implementation Plan were published by the Department of Finance this week. They set out 30 actions intended to strengthen Ireland's defences against illicit finance ahead of the country's Mutual Evaluation by the Financial Action Task Force (FATF) in 2028.
‘It's encouraging to see the Government finally moving to close some of the most glaring loopholes that TI Ireland and our partners have spent years highlighting, from secretive limited partnerships to unverified company registrations, said Dr Alexander Chance, Head of Policy and Research at TI Ireland.
‘But a plan to fix Ireland's defences against dirty money can only succeed if it fully responds to the nature and scale of the threat. Ireland is a major international financial centre, for example hosting over €5 trillion in domiciled investments funds, making it the second largest such financial centre in the EU. The real risk we face is not just from domestic crime, but the laundering of the proceeds of foreign corruption and organised crime through Irish-registered companies and other financial structures – facilitated, wittingly or not, by the professionals who service them. That risk is acknowledged in places in the NRA but needs to be carried through consistently into the actions that follow’, Dr Chance added.
Welcome progress on long-standing recommendations
TI Ireland found that several commitments in the Action Plan respond directly to recommendations the organisation has made repeatedly. These reflect findings and proposals in TI Ireland reports including ‘Safe Haven?’ (2021), ‘Weak Links’ (2024) and its May 2026 Policy Explainer, ‘Up to the Task?’. They also reflect TI Ireland’s various submissions to Government and the Oireachtas Finance Committee.
Positive commitments include:
- Mandatory disclosure of the beneficial owners of all Limited Partnerships. The Government will also consider limiting or prohibiting general partners who are corporate entities and/or are based in secrecy jurisdictions (Actions 16 and 17).
- Independent verification of information submitted to the companies register. This responds to weaknesses in the company registration regime exposed by journalists five years ago (Action 18).
- New powers of pecuniary sanction for all AML/CFT supervisors. There will also be a formal annual review of supervisory priorities and resourcing (Actions 25 and 28).
- Enhanced data collection and analytical capacity for FIU Ireland and the Office of the DPP. A new framework will support parallel money laundering and tax investigations (Actions 1 and 30).
- Acknowledgement of the importance of beneficial ownership (BO) data in tackling illicit finance. There is a commitment to examine interoperability between Ireland's three BO registers to enable effective cross-checking and data verification (Action 14).
- Legislation to require publication of a list of Special Purpose Entities (SPEs) availing of the Section 110 tax regime and to require a unique ‘Legal Entity Identifier’ for such entities (Action 29).
- Recognition of the vulnerabilities created by fragmented AML supervision of Trust and Company Service Providers (TCSPs), and commitment to create a register of certain TCSPs (Action 26).
Transnational money laundering risk ‘excised’ from the State's understanding of corruption
Despite this progress, TI Ireland said the NRA's treatment of corruption remains narrowly domestic in focus. It fails to reflect the role played by international financial centres, such as Ireland, in acting as a conduit for the proceeds of overseas corruption.
‘We welcome the NRA's explicit acknowledgement that Ireland's role as an international financial centre carries ‘inherent exposure to transnational ML threats’, and the Central Bank's commitment to analyse cross-border financial flows’, said John Devitt, Chief Executive of TI Ireland. ‘But this same threat is absent from the NRA's assessment of corruption itself. The single biggest money laundering case in the history of the State involved the movement of the proceeds of foreign corruption valued at up to $300 million through the IFSC in 2015. Yet, the NRA is confined to a narrow, domestic legal definition that excludes the role of professional enablers in Ireland who facilitate these crimes’.
Under-resourced law enforcement, lack of action on crypto risk
TI Ireland also raised concerns that several of the risks most clearly identified in the NRA are not matched by a proportionate commitment to action. FIU Ireland and the Garda National Economic Crime Bureau remain chronically under-resourced. This has been repeatedly flagged by domestic and international reviews. Yet resourcing is not addressed anywhere in the 30 actions, despite the scale of financial flows passing through the State.
The NRA describes the risk posed by crypto assets as ‘very significant’. But only two of the 30 actions directly address crypto-assets or new technologies. TI Ireland described this gap as a missed opportunity to match the scale of the threat with an appropriate response. As well as increased law enforcement training on crypto-assets, other areas that would benefit from increased scrutiny and action include ‘peel chains’ (low value but high volume crypto ‘hops’ or transfers), the risks of unhosted or non-custodial wallets for peer-to-peer transactions, and the use of crypto-assets to purchase high value goods.
TI Ireland further highlighted the absence of any sustained scrutiny of strikingly low reporting levels in certain sectors. For example, the funds industry submitted just 480 Suspicious Transaction Reports (STRs) out of a total of more than 35,000 STRs in 2024, despite managing or administering assets worth over €5 trillion. The NRA records this figure without any comment.
In addition, TI Ireland noted that 90% of Special Purpose Entities reportedly fall outside the scope of AML supervision, according to the Central Bank. This means that even the new transparency measures proposed for Section 110 vehicles will leave the bulk of these vehicles unsupervised.
Civil society excluded from two-year NRA process
TI Ireland expressed particular concern about the drafting process. It took two years to deliver the NRA, yet neither the Department nor its contractors sought input from TI Ireland or, as far as the organisation is aware, any other civil society organisation.
‘It’s now well established, including in FATF's own guidance, that drawing on a wide range of perspectives – including those that challenge prevailing assumptions and orthodoxies – is critical to understanding and responding to financial crime risk’, Mr Devitt said. ‘The Action Plan itself lists collaboration with civil society as one of its high-level priority actions. Yet at no point during the two years of the NRA’s development were we, or to our knowledge any other civil society organisation, approached for our views. That is not a technicality. It calls into question the credibility of the commitment to engage with civil society, and it is a missed opportunity that weakens the Government's own risk assessment’.
Calls for further action
TI Ireland is calling on the Government to:
- Commit additional, ring-fenced resourcing and specialist staffing for FIU Ireland and the Garda National Economic Crime Bureau, commensurate with the scale of financial flows through the State;
- Expand the Action Plan's response to crypto-assets and emerging technologies beyond the two measures currently proposed;
- Investigate and address the disparity in Suspicious Transaction Reporting between different sectors and professions;
- Address the lack of AML supervision of Special Purpose Entities and ensure that new transparency measures around SPEs are matched by proportionate AML oversight;
- Restore meaningful ‘legitimate interest’ access to beneficial ownership data, as required under the EU's anti-money laundering framework, and ensure that BO data is adequately verified;
- Increase the transparency and accountability of AML efforts, including by publishing regular progress reports on delivery of the 30 priority actions ahead of the 2028 FATF Mutual Evaluation.
- Commit to an ongoing, formal mechanism for engagement with civil society on the implementation of the AML action plan and future risk assessments and analysis.
‘TI Ireland and our international colleagues will continue to engage constructively with the Department of Finance and other state bodies on the implementation of this plan’, Dr Chance added. ‘The integrity of our financial system, as well as Ireland's credibility ahead of our 2028 FATF evaluation, depend on addressing all of the weaknesses that leave Ireland open to being used as a conduit for the world's dirty money’.
TI Ireland's resources and previous reports on illicit finance, including ‘Safe Haven? Targeting the Proceeds of Foreign Corruption in Ireland’ (2021) and ‘Weak Links: Irish Corporate Structures and Illicit Financial Flows’ (2024), are available at: https://transparency.ie/resources/dirty-money