Central Bank Of Ireland Publishes Second Edition Of Its Financial Crime Bulletin

In July 2026, the Central Bank of Ireland (CBI) published the second edition of its biannual Financial Crime Bulletin, which provides an update on key regulatory developments in the areas of Anti-Money Laundering (AML), Combatting the Financing of Terrorism (CFT), Financial Sanctions (FS), Fraud and Market Abuse. A link to the Bulletin can be found here.

Building on the feedback received since the publication of the first edition in December 2025, the Bulletin addresses the following topics:

• Risks and priorities;

• AML data collection update;

• AMLA developments;

• Tackling fraud and scams;

• EU financial sanctions and trusts; and

• Reporting market misconduct.

A summary of the developments in these areas can be found below.

Risks and Priorities

Ireland’s National Risk Assessment (NRA) was published in June 2026 and identified financial crime risks and priorities at national level. A new Priority Action Implementation Plan, published alongside the NRA, intends to strengthen the State’s response to financial crime.

Key findings from the NRA include the following:

• The overall money laundering (ML) threat for Ireland is considered “Moderate”, with the highest risks deriving from drug offences and fraud;

• Terrorist financing (TF) and proliferation financing (PF) threats are deemed to be “Low”;

• Investment fraud has risen dramatically and 44% of investment fraud reports reference cryptocurrency, suggesting that criminals are favouring rapid fund movement beyond regulatory reach; and

• Traditional retail banks, digital banks, e-money institutions, payment institutions and crypto-asset service providers (CASPs) present “Very Significant” ML and TF risks.

The Regulatory & Supervisory Outlook Report 2026 also outlines the CBI’s priorities when tackling specific financial crime risks and vulnerabilities in the financial sector. Banking, payments, e-money and the investment funds sectors are all identified as key priority areas for supervision.

The payment and e-money sectors have inherently high exposure to the risk of financial crime due to the diverse and complex nature of the business models involved. Firms must have effective governance arrangements, systems and controls in place which are proportionate to the nature, scale and complexity of their business and the risks they face. AI-driven social engineering has become a major threat in this area and has contributed to a recent increase in cybercrime and fraud.

AML/CFT also remains a key supervisory focus in the crypto-asset sector. The opaque and rapidly evolving nature of the market structures in this sector means that the CBI expects firms to maintain effective AML and fraud-prevention controls to mitigate financial crime risks.

AML Data Collection Update

The CBI notes that it has already published AML/CFT Risk Evaluation Questionnaires (REQs) for credit institutions, payment institutions, e-money institutions, investment firms, CASPs, life insurance companies and credit unions. It will continue to publish sector-specific REQs on its website in H2 2026 and will contact firms individually about their submission obligations. Submission dates for sectors submitting REQs relating to 2024 and 2025 data will be staggered throughout 2026. For 2026 data, the submission date will be March 2027, to align with AMLA’s reporting framework. Each year thereafter, the annual REQ submission date will occur in March for the preceding calendar year’s data.

AMLA Developments

In February 2026, AMLA published its Single Programming Document (SPD)for 2026 to 2028. The SPD sets out the main structures of AMLA, the Executive Board and the General Board, and their compositions. It also provides an overview of AMLA’s scheduled mandates for 2026 and states that AMLA’s strategic objectives are focused on the completion of the Single Rulebook, the advancement of supervisory convergence and the strengthening of cooperation among Financial Intelligence Units (FIUs). AMLA is encouraging firms to participate in ongoing public consultations and public hearings, while the CBI also welcomes feedback on the changes being made at EU level.

Tackling Fraud and Scams

The CBI highlights a significant increase in the frequency and complexity of financial scams and frauds targeting consumers. Speaking on the OECD Report on Protecting Consumers from Financial Frauds and Scams, published in June 2026, CBI Deputy Governor for Consumer and Investor Protection, Colm Kincaid, called for comprehensive action and a coordinated response from all actors in the system.

The CBI also cites its own research from April this year, which showed the importance for victims to report fraud to their bank, An Garda Síochána or another relevant authority. 57% of those who reported fraud were able to recover money lost, while just 13% of those who did not report the fraud recovered money.

The CBI is currently carrying out a thematic review of authorised push payment fraud in the banking and payment sectors, which it expects to inform the updated supervisory expectations it will issue for firms. These will include putting measures in place to prevent, detect and report fraud, and to take a consumer-centric approach when supporting customers who fall victim to frauds and scams. There has also been an increase in reports of fraud loss recovery scams, in which scam artists claim they can help victims of fraud recover lost funds for an upfront fee.

As part of the effort to break the link between the perpetrators and the victims of frauds and scams, the CBI published its first Report on Activities under the Digital Services Act in April 2026.

EU Financial Sanctions and Trusts

The CBI references three recent landmark judgments delivered by the European Court of Justice¹, which established that EU sanctions against a sanctioned individual extend to trust assets if the individual exercises substantive control or influence over them, rather than just holding formal legal title over those assets. This “substance over form” test essentially means that formal trust structures alone cannot shield assets from sanctions. Economic operators will need to carry out thorough, case-by-case evaluations, which extend beyond legal documentation and conduct, to determine whether a sanctioned person retains control or influence over the trust assets in question.

If this determination is made, or if there is a reasonable ground for suspicion of such, the trust assets must be frozen and the activity must be reported to An Garda Síochána and the CBI Financial Sanctions Team at sanctions@centralbank.ie.

Reporting Market Misconduct

As market abuse is difficult to identify, the CBI relies heavily on Suspicious Transaction and Order Reports (STORs) to provide valuable intelligence in assisting in the detection and investigation of market misconduct. The CBI reiterates its stance in this Bulletin that firms need to be proactive in STOR reporting and that reporting should be backed by effective surveillance, robust escalation procedures and timely reporting. The CBI is currently conducting a thematic assessment of market abuse frameworks in a cross-section of firms, with the aim of identifying where firms and the CBI can do more.

Footnote

1 Delivered on 21 May 2026 – see Case C-483/23 (T Trust), C-428/24 (FZ AR) and C-476/24 (SX).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.