On 18 March 2021, the President signed into law the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 (the Act).  The Act, which has not yet commenced, transposes most of the European Union’s Fifth Anti-Money Laundering Directive into Irish law and amends the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended in 2018).  

Although some material matters have yet to be addressed, changes introduced by the Act include: 

• the extension of the anti-money laundering regime to certain virtual asset services providers, property services providers, and high-value art dealers and intermediaries;
• new obligations on designated persons (including life insurance companies) to check beneficial ownership registers;
• more circumstances where customer due diligence (CDD) must be conducted and enhanced CDD for high-risk third countries; and
• a broadened definition of “politically exposed person” to include “any individual performing a prescribed function”. 

If you would like to know more about the services we offer or have any questions about the Act, please contact our partners listed here or your usual contact at William Fry. 

Contributed by James Foster