The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act, 2018 (2018 Act), which gives effect, in part, to the Fourth EU Anti-Money Laundering Directive (2015/894) under Irish law was commenced on 26 November 2018. The 2018 Act increases the obligations on regulated firms to put in place systems and controls to prevent and detect money laundering and terrorist financing.

On 21 December, the Central Bank published Consultation Paper 128, which contains draft guidelines (the Guidelines) that set out the expectations of the Central Bank in respect of firms' compliance with their AML/CFT obligations following the enactment of the 2018 Act. The Central Bank invites general feedback on the Guidelines from interested stakeholders, including regulated financial firms and requests that respondents consider the specific questions contained in section 5 of the Consultation Paper.

Respondents are required to submit their feedback by email using the template provided in schedule 2 of the Consultation Paper to The closing date for making submissions is 5 April 2019.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.