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AML (Anti-Money Laundering)

aka anti-money laundering, AML compliance, CTF, anti-money laundering and counter-terrorist financing

The legal and procedural framework that banks and electronic money institutions must operate under to detect and prevent money laundering and terrorist financing. AML compliance is a condition of holding a banking or e-money licence from the Central Bank of Ireland.

Last reviewed May 2026

Definition

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations are set out in Irish law under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, which transpose the EU Fourth and Fifth Anti-Money Laundering Directives (4AMLD and 5AMLD) into Irish statute. The Central Bank of Ireland supervises compliance for banks and electronic money institutions operating in Ireland. For Irish fintech platforms and business banking providers, AML obligations include: 1. Know Your Customer and Know Your Business: Verifying the identity of individual customers (KYC) and business customers (KYB) before providing services. See the KYB entry for the Irish-specific documentation requirements. 2. Transaction monitoring: Ongoing automated screening of transaction patterns against risk thresholds. Unusual patterns - sudden large cash-equivalent inflows, rapid movement of funds through multiple accounts, unusual geographic patterns - trigger Suspicious Transaction Reports (STRs) filed with the Financial Intelligence Unit (FIU) at An Garda Siochana. 3. Sanctions screening: Checking customers and counterparties against EU, UN, OFAC, and UK sanctions lists. Post-2022, Russia and Belarus-connected entities are a high-priority screening category for Irish financial institutions. 4. Enhanced Due Diligence (EDD): Applied to higher-risk customers including Politically Exposed Persons (PEPs), customers in higher-risk jurisdictions, or businesses in cash-intensive sectors. For Irish SMEs, AML compliance manifests primarily during account opening (KYB documentation requirements) and occasionally in requests for source-of-funds information when transaction patterns trigger enhanced review. A legitimate Irish business receiving a large payment from an overseas client, or moving funds between group entities, may be asked by its fintech platform to provide documentation explaining the transaction - this is a standard AML compliance step, not an accusation of wrongdoing. AML requirements are not optional for regulated platforms. A fintech that fails to implement adequate AML controls risks licence revocation by the Central Bank of Ireland. Irish SMEs should treat AML document requests from their platform as a normal compliance interaction and respond promptly with clear documentation to avoid account restrictions.

Why it matters for software choice

Irish SMEs that understand AML requirements can prepare documentation proactively during account onboarding (company registration, UBO information, expected transaction volumes and geographies) and respond quickly when their platform requests source-of-funds verification. Slow or incomplete responses to AML requests are the most common reason for business account restrictions on fintech platforms.

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