5AMLD What Are the Key Changes?

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[vc_row][vc_column width=”1/1″][vc_column_text]The EU’s Fifth Anti-Money Laundering Directive (5AMLD) was transposed into Irish law by way of the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021.

What is changing? 

The Central Bank of Ireland (‘CBI’) have published a revised version of its Anti-Money Laundering and Countering the Financing of Terrorism Guidelines for the Financial Sector.

Why was a revision made? 

As well as the changes to Irish law, the Guidelines also reflect the expectations of the CBI as set out in their October bulletin and the European Banking Authority Risk Factor Guidelines.

What’s new?

Here are some highlights:

Customer Due Diligence 

  • Firms have obligation to identify the beneficial owners of their customers, verify their identity and confirm that information concerning such beneficial ownership is entered in the relevant register.
  • Firms are now required to apply specific Enhance Due Diligence measures when dealing with a customer established or residing in a high-risk third country and  in high-risk situations.
  • The Guidelines provide additional requirements around transacting with Politically Exposed Persons (PEPs)

Risk Management

  • As before Firms are required to apply a risk -based approach when apply AML/CFT measures. A Firm should identify the risk the Firm is potentially exposed to, given its particular business which in turn will assist in assessing the risk from transacting with a customer or performing an occasional transaction.
  • The CBI also advises Firms when applying a risk -based approach, to “be cognisant of the importance and benefits of financial inclusion”. Proper documented consideration must be given to all risks and possible mitigants before wholesale termination of business relationships

Transaction Monitoring

  • The CBI reiterates its position that automated transaction monitoring is ‘desirable’ while warning that a Firm cannot place absolute reliance on such a system. It is important that employees are still in a position to manually identify transactions that may be suspicious and that any automated solution is regularly reviewed and interrogated.


  • The Guidelines confirm the critical importance the CBI places on the attitude and culture of a Firm when it comes to AML/CFT compliance. This is best reflected in a robust governance model involving the Board, senior management including the Compliance Officer and/or MLRO and internal audit.

What can ID-Pal do for your business? 

The Guidelines confirm that CBI’s position that Firms can utilise Reg Tech Solutions to assist with their AML/CFT compliance obligations.

The CBI advises Firms when using Reg Tech solution to ensure they:

  • Fully understand the impact the RegTech solution has on the Firm’s regulatory compliance:

ID-Pal’s enables your business to satisfy AML and KYC requirements. Every business has unique compliance needs and finding solutions and tools that are the right fit for your company, that grow with your business and also meet your regulatory obligations is key.

  • Ensure that the RegTech solution can achieve compliance for the Firm with its relevant AML/CFT obligations when the RegTech solution goes live;

The ID-Pal solution is fully customisable and moulds to the KYC needs of your business. The platform uses industry-leading biometric, document and database checks to verify that documents have not been forged or tampered with and that the individual submitting an identity document is its rightful owner.

  • Ensure that the RegTech solution is capable of being audited by an independent third party;

As an ISO27001 Certified business and to maintain this industry-leading certification, audits are regularly completed. ID-Pal is in constant pursuit of audit excellence – read more here

  • Undertake a compliance risk assessment of the RegTech solution on an annual basis either independently of, or incorporated into, the Firm’s annual AML/CFT risk assessment

Our solution provides best-in-class management to keep customer data safe. All data is encrypted and available only to our customer. As experts in encryption, security and privacy, we implement secure systems and operate critical identity verification services for our customers.

Given the ever-changing regulatory landscape and rapid pace of technology, ID-Pal continues to stay informed of any legal changes that could impact our customers and strives to share our findings in the most helpful way.


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Contact us today for a live demo of how the ID-Pal service can be easily integrated with your business.

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