Transparency International (TI) Ireland has broadly welcomed the Government's first National Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing (AML/CFT/CPF) Strategy, launched on 13 August 2026 by Tánaiste and Minister for Finance Simon Harris, while warning that some important questions remain outstanding.
The new Strategy builds on the 2026 National Risk Assessment (NRA) and Priority Action Implementation Plan published in June, to which TI Ireland has already set out a detailed response.
Overall, it suggests that the Government is increasingly willing to acknowledge the risks and responsibilities that accompany Ireland’s role as a leading global financial centre; to recognise the national security implications of dirty money; and to commit to reforming specific areas – such as opaque Irish corporate structures – that were previously ignored or downplayed. TI Ireland welcomes these developments, which we have been calling for over several years.
However, whilst the Strategy suggests a more sophisticated response to illicit finance, the Government’s past record on this topic has been underwhelming, especially in relation to international risks. The Financial Action Task Force (FATF) Mutual Evaluation of Ireland in 2028 will need to see evidence that the ambition and commitments in the Strategy and Action Plan are carried through into concrete activities, and that those actions are effective in practice.
Strengths
In particular, TI Ireland welcomes the following aspects of the new Strategy:
- Explicit acknowledgement of the serious and strategic risks posed to Ireland by illicit finance, including to the integrity and stability of our financial system, to the facilitation of organised crime, to wider societal cohesion, and to our national security.
- Recognition of Ireland’s international responsibilities as a leading global financial centre, with a specific commitment that Ireland’s approach to ML/TF/PF should ‘not become a weak link in the interconnected international financial system’.
- Strong commitment to a multi-agency, cross-government approach to AML/CFT that also facilitates private sector perspectives and exchanges through ongoing, structured collaboration and intelligence-sharing mechanisms.
- Acknowledgement that organised crime groups active in Ireland use increasingly sophisticated money laundering techniques, including international financial channels, virtual assets and complex or opaque corporate structures.
- Emphasis on a more consistent, coordinated and risk-based approach to AML supervision, including via formal annual reviews, as recommended by TI Ireland in our May 2026 assessment of Ireland’s AML supervisory framework.
- Ambition ‘to ensure that Ireland not only meets the legal requirements of the EU AML package, but also that the measures put in place will contribute towards a more effective [AML/CFT] framework’, per FATF’s focus on effectiveness.
- Recognition of the importance of oversight of Trust and Company Service Providers (TCSPs) as an AML/CFT measure, including greater visibility of TCSPs supervised by designated accountancy bodies and consideration of a single register of all TCSPs in Ireland.
- Implicit recognition of the importance of beneficial ownership (BO) as a key AML/CFT tool, with a commitment to increase the transparency and scope of BO information, to strengthen the powers of BO Registers, and to seek to mandate BO disclosure for all Limited Partnerships.
Outstanding questions
However, the Strategy leaves several questions unanswered:
- Whilst the Strategy commits to increased State collaboration with civil society to identify emerging risks and challenges, and to support analysis, there are no mechanisms proposed to facilitate this wider, ‘whole-of-society’ exchange, akin to those with the private sector.
- Whilst the strategy commits to allocating resources to areas of greatest risk, and to sufficiently resourcing law enforcement with ‘tools, expertise, and specialist capabilities’, previous domestic and international calls for greater FIU and GNECB resourcing have gone unheeded.
- Although the Strategy makes some reference to the AML/CFT challenges posed by crypto-assets and wider technological developments, this area remains underdeveloped given that the NRA correctly assessed the laundering risk posed by crypto as ‘very significant’.
- Although the Strategy reinforces commitments in the Action Plan to reduce the opacity around Limited Partnerships and Special Purpose Entities, to date the Government has shown little urgency to close these gaps, given they were first highlighted several years ago.
‘A first national AML strategy is an important milestone, and today's announcement promises real progress on issues we have raised for years’, said Dr Alexander Chance, TI Ireland’s Head of Policy and Research.
‘But Ireland's credibility ahead of the 2028 FATF evaluation depends on matching the Strategy’s ambition with effective implementation of its commitments. It will also require providing adequate FIU and Garda resourcing, genuine whole-of-society engagement, rapid action on crypto and emerging technologies, and the closure of long-standing loopholes in corporate structures’, he added.
TI Ireland's resources on illicit finance, including its previous reports and response to the NRA and Action Plan, is available at: transparency.ie/resources/dirty-money.