In July 2021, the European Commission proposed the establishment of a new EU authority to counter money laundering and the financing of terrorism (AML/CFT); the EU authority will be called AMLA (Anti-Money Laundering Authority). The Irish Government has declared an interest in hosting AMLA, alongside a list of nine other EU countries also bidding to host what will be a significant EU institution when it becomes fully operational in 2026/7.
Aidan Clifford, FCCA, FCA, is the Advisory Services and PA Manager in ACCA Ireland.
Money laundering and terrorist financing thrives in environments with varying rules and hard national borders. A single rule book and maximum EU cooperation will make the laundering of criminal proceeds in the EU significantly more difficult. It would also be desirable for both the UK and the US, as major centres of finance and banking, to engage extensively with the EU rule book. Because of the land border with the UK, our position as the US’s gateway to Europe, and the historical ties between all three countries, hosting AMLA in Ireland would present a unique opportunity to align these major financial jurisdictions with the EU’s rule book.
AMLA will initially directly supervise at least the 40 largest and highest risk banks and financial institutions where the financial institution has a presence in several Member States. Most of these entities already have operations in Ireland, with some also having their centralised AML/CFT compliance function located in Dublin. Ireland hosts over 500 global financial institutions and 15 of the top 20 global banks. Although one of the smaller EU populations, Ireland is reported to be the 6th largest exporter of financial services in the EU. There are over 90,000 people employed in the financial services sector in Ireland.
The small city of Dublin, with an existing concentration of financial services providers, allows for supervisors, law enforcement and supervised entities to cooperate in the interests of strengthening the framework within a culture of collaboration. Ireland also nourishes a culture of innovation, with FATF (Financial Action Task Force) calling out Ireland’s leadership and innovation with regards to asset recovery. This ecosystem of collaboration, innovation and close working relationships means Ireland scores highly on FATF financial sector supervision, well ahead of many larger countries. Ireland demonstrates this collaboration, innovation and close working relationships within domestic AML/CFT supervision arrangements through a number of existing private sector and Government consultative forums. These forums analyse discuss and collaborate on solutions to address emerging risks and trends and are also used to communicate issues through the various economy sectors that may be affected by money laundering.
Finding the right talent to run AMLA will be a challenge for any country, but Ireland has had a head start. ACCA began a project five years go to create a centre of excellence in AML/CFT in Ireland and as a result of this initiative there are ten providers of specialist Government supported training in AML/CFT, and additional training providers in the related fields of automation analytics and AI. There is now a large cohort of qualified people who have completed the required training and they are available to provide the core Dublin-based staffing requirement for AMLA. ACCA membership data shows that approximately 5% of all accountants in Ireland are non-Irish EU nationals, with every EU country represented within that membership; most EU countries are likely to be represented within a Dublin headquartered AMLA.
Many of the headquarter staff in AMLA will be arriving from other EU countries and bringing their families. Although there is a need for more accommodation in Dublin, high-quality housing is available, and the work of AMLA is ideally suited to hybrid working. Staff will be able to avail of plentiful idyllic inexpensive rural living opportunities for their family’s while being within commuting distance to Dublin for in person meetings. Ireland enjoys widespread availability of highly rated, state funded and private, primary and secondary education along with eight universities, 6 of which are in the top 500 universities globally, and in January 2023 was rated one of the top 25 countries in the world to raise a family.
Ireland is the only fully English-speaking country bidding for AMLA. The advantage of speaking the universal business language becomes more apparent when considering the entities likely to become directly supervised; many will be US or far-east headquartered. Ireland benefits from a strong relationship with the US and many of the largest US banks already have operations here. Ireland also has a growing relationship with the far east.
Small Member States are subject to the same AML/CFT rules as larger ones but have considerably less resources. Through no fault, those smaller countries can experience a greater struggle in trying to ensure application of AML rules and standards. Although Ireland has always scored well on FATF reviews, the influence of a smaller country’s perspective would serve to strengthen AMLA’s function. Ireland would have a more immediate awareness of the compliance challenges faced by smaller countries and therefore tailor guidance and advice to ensure compliance is as easy in a small nation as it is in largest EU countries. Assisting and working with countries that struggle to comply not because of attitude, but rather, resources.
This year Ireland is celebrating 50 years of EU membership. From the 83% of Irish people who voted to join the EEC as it was at that time, the level of support for the EU has ranged from 70% to 90% ever since. Ireland does not have any other major EU authority headquartered on the island but is ideally placed and resourced to host AMLA.
