Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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217. To ask the Minister for Finance whether the banking and financial regulatory framework in Ireland is sufficient to detect and mitigate schemes involving large-scale ATM withdrawals conducted over short periods, especially where funds have been lodged abroad and withdrawn in Ireland; and whether any regulatory enhancements are planned. [50120/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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The Finance (Provision of Access to Cash Infrastructure) Act 2025 introduced a requirement for the Central Bank of Ireland (CBI) to collect and publish detailed information on ATM infrastructure including the number, location and hours of availability of ATMs and where prescribed by the Minister, the number and value of withdrawals and the denominations dispensed.

The Act also gives the Central Bank of Ireland powers to require information and records from designated entities, ATM operators and cash-in-transit (CIT) providers, which would provide significant visibility over the functioning of the cash network. The Act brings ATM operators and CIT providers into the regulatory perimeter of the CBI and protects the resilience of the cash system.

Additionally, Ireland’s legislation for anti-money laundering and combating the financing of terrorism (AML/CFT) is largely contained within the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (‘the 2010 Act’).

This establishes a comprehensive framework for the prevention of money laundering and terrorist financing, including by setting out reporting and examination requirements applicable to ‘designated persons’, which refers to persons with AML/CFT obligations such as credit and financial institutions, where there have been suspicious transactions.

Regulatory reform has been underway at EU level to strengthen the framework for AML/CFT, as a Sixth AML Directive and a first AML Regulation were published in July 2024. Most elements of the Directive, including the powers of AML/CFT supervisors and enforcement agencies, will require transposition by July 2027. Most provisions of the Regulation, which include the requirements applicable to ‘obliged entities’ (which has the same meaning as ‘designated persons’), will also apply from July 2027.

As the Regulation will introduce directly applicable requirements across all 27 Member States, it will provide for a harmonised and strengthened framework for AML/CFT across the European Union.

Work is ongoing between my Department and the Department of Justice, Home Affairs & Migration on the necessary transposing legislation.

At the EU level, The Financial Action Task Force (FATF) sets international Anti-Money Laundering/Countering the Financing of Terrorists (AML/CFT) standards (known as FATF Recommendations). The FATF Recommendations set out a comprehensive framework of measures which countries should implement in order to combat money laundering and terrorist financing, as well as the financing of proliferation of weapons of mass destruction.

The EU brings the FATF Recommendations into EU Law through the EU’s AML Directives and Regulations, which are in turn transposed into national law frameworks by the EU Member States (e.g. The Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010).

FATF Recommendation 16 sets out the rules regarding the information relating to persons sending and receiving funds that payment service providers (including Banks) must collect so that such information is readily available to law enforcement who require such information when investigating suspicious transactions. Recommendation 16 is sometimes referred to as the “Travel Rule”, because the required data of the transacting parties ‘travels’ along with their fund transfers.

FATF have recently carried out public consultations on proposed amendments to FATF Recommendation 16. As part of the proposed amendments, the FATF identified some deficiencies in respect of the timeliness at which information is made available to financial institutions in relation to cross-border cash withdrawals, which could lead to delays in the detection and reporting of suspicious activity to law enforcement agencies.

Accordingly, FATF considers that it is necessary to address this issue by amending Recommendation 16 with a targeted requirement for cross-border cash withdrawals. These amendments focus on achieving greater transparency of information regarding cross-border cash withdrawals, and more efficient and effective AML/CFT controls by financial institutions and authorities fighting financial crime.

While the existing framework does allow for the sharing of information relating to cross-border ATM withdrawals with law enforcement agencies, these forthcoming changes will increase the speed at which the required information on suspicious transactions is made available.

Ken O'Flynn (Cork North-Central, Independent Ireland Party)
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218. To ask the Minister for Finance whether there are known vulnerabilities in cross-border bank lodgements and withdrawals across EU Member States which are being exploited in the movement of illicit funds; the specific steps his Department is taking to strengthen cross-border cooperation; and whether current EU legal instruments are adequate for preventing such abuse. [50122/25]

Paschal Donohoe (Dublin Central, Fine Gael)
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Domestically, the Department of Finance chairs the Anti-Money Laundering Steering Committee, which provides a national, cross-sectoral forum for the active review of Ireland’s anti-money laundering and combating the financing of terrorism (AML/CFT) framework.

Work is currently underway on updating Ireland’s AML/CFT national risk assessment. This includes consultation with various stakeholders and review of the risks faced across multiple sectors and activities.

Our first national risk assessment was published in 2016, which aimed to identify, understand and assess the AML/CFT risks faced by Ireland, including in the financial services sector. In relation to the retail banking sector this concluded ‘.... the overall ML/TF risk within the Irish retail banking sector is judged to be High, due to the nature, scale and complexity of the sector and its central role in Irish financial services, offering core banking services to a broad population and acting as the gateway to the wider financial sector.’

Credit and financial institutions have legal obligations under Irish AML/CFT legislation and are required to employ risk-mitigating measures.

The most recent supranational risk assessment published by the European Commission in 2022 similarly assessed the risk level for money laundering in the EU’s retail banking sector as Very High. This assessment was accompanied by a number of identified mitigating actions, several of which form part of new EU legislation which was subsequently finalised in 2024.

The Department of Finance took the lead role for Ireland in the negotiations of this legislative package, to address AML/CTF issues. Arising from this, the Sixth AML Directive includes measures relating to the tasks and powers of national competent authorities, which must be transposed by July 2027. The bulk of the separate Regulation, which contains measures applicable to obliged entities, meaning persons with AML/CFT obligations, will also apply from July 2027. Collectively, they will provide for a strengthened and harmonised AML/CFT framework across the entire EU.

Work is ongoing between the Departments of Finance and Justice on transposing this legislation.

Separately, measures to ensure cross-border cooperation is facilitated at EU level include the creation of an EU Anti-Money Laundering Authority (AMLA).

Accordingly, this agency will act as a central supervisor for AML/CFT and is also mandated to facilitate cooperation between Financial Intelligence Units (FIUs) and AML/CFT supervisors in both the financial and non-financial sectors.

Its General Board will now serve as Ireland’s primary avenue for engagement with the Authority. In its supervisory composition, Ireland’s representative is an official from the Central Bank of Ireland, while in FIU composition, the head of FIU Ireland is Ireland’s representative.

Finally, it should be noted that AML/CFT is a highly dynamic policy area, with ongoing work required to address new and emerging challenges. The Financial Action Task Force ( FATF) which sets international standards for AML/CFT, regularly updates its standards and guidance in response to emerging risks and trends. The need for ongoing work is also reflected in the ongoing revision of EU legislation to address identified issues, as outlined above.