The Government has published its strategy for combating high-level financial crime. The cumbersomely titled National Anti-Money Laundering, Countering the Financing of Terrorism and Countering Proliferation Financing Strategy 2026 outlines how the State will respond to the ever-increasing complexity of this type of criminal activity.
It sets a number of policy objectives, including increased cooperation across government departments, law enforcement agencies and regulators. One of its priorities is preparing for the implementation of the European Union’s new anti-money-laundering framework, which will see the creation of an EU-wide Anti-Money Laundering Authority (AMLA). It also calls for more focus on crypto assets and other less regulated financial instruments.
The strategy document follows on from the publication earlier this year of the 2026 National Risk Assessment and Action Plan, which set out actions to address the new threats and risks dealt with in the strategy document. Reassuringly, it found that risks were generally low.
The implementation of the action plan is one of the objectives of the strategy. This is somewhat circular in nature. Action plans normally follow on from a defined strategy setting out objectives.
RM Block
This approach leaves the latest document, published without any fanfare, open to the accusation that it is little more than a box-ticking exercise for the European Union and other external observers.
A counterargument is that the document merely formalises the strategy developed as part of the risk assessment and action plan process. It is probably a bit of both.
The external audience is important. Ireland is the third-largest exporter of financial services in the European Union and the eighth largest globally. Intangible financial service exports such as aircraft leasing, insurance and fund administration are worth € 11 billion and account for over 6 per cent of gross domestic product and around 50,000 jobs.
Financial service exports are one of the less celebrated ways in which we have leveraged our membership of the EU, educated workforce and regulatory credibility. Maintaining the confidence of our international interlocutors is important and includes demonstrating a coherent strategy when it comes to dealing with money laundering and other new financial crimes.
The strategy document published this week contributes to that. The proof of the pudding is in the eating, however, and the action plan, which requires buy-in from the Defence Forces, An Garda Síochána, regulators, Revenue, the Central Bank and the Departments of Foreign Affairs and Justice, must be implemented with the determination it merits.
