Guidance on Risk 

It is important for supervisors and designated persons to be aware of risk factors when conducting its risk assessment and to apply an effective risk-based approach. Risk factors can fall under categories including customer, products/services, geography and channels/distribution.

There is a range of sources where guidance on money laundering (ML) and terrorist financing (TF) risk and applying a risk based approach to supervision and preventive measures can be accessed, some of which is set out below.

National Money Laundering and Terrorist Financing Risk Assessment

The Department of Finance and the Department of Justice and Equality have published Ireland's first Money Laundering and Terrorist Financing (ML/TF) National Risk Assessment (NRA).

The NRA is an assessment of the ML/TF threats in Ireland and the vulnerabilities of certain sectors to being used for ML/TF as a result of the products and/or services they offer, their customer base, the countries in which they operate and the delivery/distributions channels they utilize. As such, the NRA is an important source for financial institutions to support and inform their own ML/TF risk assessments.

Please see links below where the NRA can be accessed:
Department of Finance

Department of Justice

European Guidance on Money Laundering and Terrorist Financing Risk

The European Supervisory Authorities (ESAs) are mandated under the Fourth EU AML Directive to publish guidance on risk factors.  They have published guidelines on carrying out risk assessments and risk factors (Risk Factors Guidelines) to be taken into consideration when applying simplified and enhanced customer due diligence. The Risk Factor Guidelines come into effect on the 26 June 2018.

The European Commission has published a Supra-national risk assessment of the risk of ML and TF across the EU that can be accessed at European Commission Supranational Risk Assessment

The European Union has identified high-risk third countries with strategic AML/CFT deficiencies that are set out in Annex to the Commission Delegated Regulation supplementing the 4th EU AML Directive.

The Delegated Act is legally binding on member states and must be complied with by designated persons.

European Joint Guidelines to prevent terrorist financing and money laundering in electronic fund transfer

On 26 June 2015, Regulation (EU) 2015/847 on information accompanying transfers of funds (Regulation (EU) 2015/847) entered into force. This Regulation aims, inter alia, to bring European legislation in line with Recommendation 16 of the International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation, which the Financial Action Task Force (FATF), an international anti-money laundering standard setter, adopted in 2012.  The ESAs have issued guidelines on this Regulation in order to promote the development of a common understanding (by payment service providers and competent authorities across the EU) of the effective procedures that are required in order to detect and manage transfers of funds that lack required information that identifies the payer and payee, and how such procedures should be applied.  A common understanding is essential to ensure the consistent application of EU law; it is also conducive to a stronger European anti-money laundering and countering the financing of terrorism (AML/CFT) regime. These guidelines must be complied with six months from their date of issue.

The statutory instrument giving effect to Regulation (EU) 2015/847 (on information accompanying transfers of funds) is available on

FATF Guidance

The Financial Action Task Force (FATF) is the international standard setting body for combating money laundering, the financing of terrorism and proliferation of weapons of mass destruction. It publishes guidance that assists in the identification of money laundering and terrorist financing threats and vulnerabilities that assist supervisors, financial institutions and designated non-financial businesses and professions (DNFBPs) to adopt a risk based approach to supervision and applying preventative measures.

The FATF identifies jurisdictions with weak measures to combat money laundering and terrorist financing (AML/CFT) in two FATF public documents that are issued three times a year. The latest list of high-risk and un-cooperative jurisdictions is set out below:

November 2017

FATF Public Statement

Improving Global AML/CFT Compliance - Ongoing Process

The FATF also publishes guidance on adopting a risk-based approach.

Guidance for a Risk-Based Approach for Money or Value Transfer Services (2016)

This guidance will assist countries and their competent authorities, as well as the practitioners in the MTVS sector and in the banking sector that have or are considering MTVS providers as customers, to apply the risk-based approach to the development of measures to combat money laundering and terrorist financing for the MTVS sector.

Guidance for a risk-based approach: effective supervision and enforcement by AML/CFT supervisors of the financial sector and law enforcement (2015) 

This guidance is intended to assist countries in developing an effective supervisory and enforcement model.

Risk-Based Approach for the Banking Sector (2014)

This guidance assists in the design and implementation of this approach for the banking sector, taking into account national risk assessments and the national legal and regulatory framework.

Risk management guidelines related to anti-money laundering and terrorist financing issued by the Basel Committee 

This guidance describes how banks should include risks related to money laundering and financing of terrorism within their overall risk management framework.