Anti money laundering training in Ireland: The complete 2026 guide

Why AML training matters in Ireland

The obligation is statutory, not best practice. Section 54 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 requires a designated person to ensure that people involved in the conduct of its business are instructed on the law relating to money laundering and terrorist financing, and are provided with ongoing training.

Two words in that sentence do most of the work. Instructed means something more than circulating a policy. Ongoing means a single induction session does not discharge it. Supervisors read both strictly.

Training is also the cheapest control a firm has. Almost every enforcement case involves someone who did not recognise what they were looking at.

Who has to do AML training?

Everyone whose work touches clients, client money or client onboarding, in any firm that is a designated person. The category is broader than most firms assume, and it covers:

• Credit and financial institutions, including insurance brokers writing life or investment business
• Auditors, external accountants and tax advisers
• Solicitors and notaries, for the transactional work listed in the Act
• Property services providers licensed by the PSRA
• Trust or company service providers
• Virtual asset service providers

Inspectors expect coverage across the firm, not only the compliance function. Reception staff who take the first call, and support staff who file the documents, are both inside the perimeter.

How often must anti money laundering training be delivered?

The Act sets no fixed interval, which is why firms get this wrong. In practice the expectation settles into three triggers:

1. At onboarding. Before a new joiner starts client work, not at the end of their probation.
2. Annually. A refresher every twelve months is the accepted cadence, and the one a supervisor will look for.
3. On material change. When the legislation moves, when guidance is reissued, or when the firm changes what it does.

A firm that trained everyone thoroughly in 2024 and has done nothing since is in breach of the ongoing limb, however good that original session was.

What should your AML training cover?

Content has to map to the Irish regime, not to a generic international syllabus. At minimum:

• The Criminal Justice Acts 2010 to 2021, and who counts as a designated person
• Customer due diligence, enhanced measures, and beneficial ownership through the RBO
• The firm-wide business risk assessment and how it drives client risk ratings
• Recognising suspicious activity in the firm’s own book, using its own products
• Internal escalation to the MLRO, and filing an STR with FIU Ireland and Revenue
• Tipping off under Section 49, and what staff must not say
• Record keeping and the six-year retention rule

Sector matters. An estate agency needs cash and beneficial ownership scenarios. A brokerage needs single-premium life bonds. Training built for neither will be picked up quickly.

What counts as acceptable evidence?

This is where most firms fall short. A signed attendance sheet proves people were in a room. It does not prove they were instructed.

• Timestamped completion records, per named individual
• An end-of-module assessment with a meaningful pass mark
• Randomised questions, so results cannot be shared between colleagues
• The exact version of the content each person took
• Six-year retention of the records and the materials

The inspector’s favourite question

“Show me what this person was taught, on the date they took it.” A firm that can produce the certificate, the outline, the score and the content version answers in seconds. A firm with a folder of slide decks does not.

Classroom or e-learning?

The Act is silent on format, and both are acceptable. The practical difference is evidence. A classroom session produces a sign-in sheet; e-learning produces a per-person record with a score attached, which is the thing being asked for.

Classroom still earns its place for a small senior group working through the firm’s own risk assessment. For firm-wide annual coverage, the record-keeping alone usually decides it.

Common audit findings, 2024 to 2026

• New joiners doing client work before any training was delivered
• An annual refresher that slipped and was never caught up
• Content still referring to superseded thresholds after an amendment
• No assessment, so no evidence anything was understood
• Generic international material with no Irish legislative basis
• Records that cannot be produced per person on request

What audit-ready actually looks like

One export. Who completed which course, on what date, what they scored, and which version of the content they took, for every person in the firm, with the certificates attached. If producing that takes more than a minute, the system is not audit-ready.

Getting there in one week

1. List everyone in the firm and the last date each was trained.
2. Pick the courses that map to your business risk assessment.
3. Enrol the whole firm with a deadline set at seven days.
4. Let the reminders chase the stragglers rather than doing it yourself.
5. Export the completion record and put it in the AML file.