Ireland snapshot: An Irish lens on the EMEA AML landscape

Efforts to prevent money laundering, terrorist financing, and the proliferation of weapons of mass destruction (collectively referred to as ‘AML’ in this survey) are becoming more challenging due to ever more sophisticated, digitally driven and cross-border threats.

Across Europe, Middle East and Africa (EMEA), the AML environment is entering a new phase defined by divergence in implementation and uneven supervisory intensity, where financial institutions of all shapes and stripes must increasingly mind the regulatory and implementation gap. In the EU, for example, the AML Package is bringing forth a whole new operational and supervisory framework which even the most sophisticated financial institutions are finding challenging to comply with.

Indeed, as regulatory expectations intensify and diverge across the EMEA region, financial institutions face sustained pressure to strengthen AML control frameworks while managing rising compliance costs. In this environment, effectiveness increasingly depends on the ability to translate regulatory change into scalable, data-driven control environments that operate reliably in practice.

Ireland is experiencing these evolving challenges in step with the broader region. Financial institutions across its diverse banking, insurance, asset management, payments and asset servicing sectors are navigating increasing regulatory complexity, growing operational demands, and compliance pressures driven by the EU AML Package and the establishment of AMLA’s supervisory model.

This study is based on a survey of 531 financial institutions across 40 countries in the EMEA region, providing a comprehensive view of the EMEA AML landscape. We leveraged PwC’s Anti-Financial Crime Network, alongside a professional market research firm, to reach targeted and relevant respondents in each jurisdiction. Respondents included major asset and wealth managers ("AWM") , banks, insurance companies, as well as electronic and virtual payments firms. Many were also interviewed personally, ensuring broader coverage across institutions and allowing for deeper insights across key areas.

Within this regional sample, Irish respondents represent a diverse cross‑section of the country’s financial services ecosystem, encompassing universal, retail, corporate and private banks; insurers; asset managers; payment institutions; asset servicing providers; and virtual asset service providers reflecting Ireland’s role as a vibrant hub in the European financial landscape.

Across EMEA, AML requirements are intensifying at a pace financial institutions are struggling to match. Between 45% and 68% of firms expect a strong or significant increase in AML capacity needs, signalling that compliance pressure has become structural rather than temporary.

In Ireland, this pressure is particularly concentrated:

• 32% of firms expect AML capacity needs to rise by 10–20%
• A further 36% expect increases of more than 20%

Taken together, 68% of Irish firms expect a material uplift in AML capacity,  aligning with the evolving EMEA landscape.

Readiness remains a critical concern. In Ireland, 40% of firms expect to be fully compliant with the EU AML Package, while only around one‑third of firms across the EU hold the same expectation. This leaves a majority of institutions in Ireland and across Europe unlikely to meet key compliance milestones on time.

Mobilisation gaps compound this risk. Only 27% of Irish firms have completed both a detailed analysis and an impact assessment of the EU AML Package — a pattern that closely mirrors slower progress observed across the EU.

When it comes to AMLA readiness and KYC gap analysis, 25% of Irish firms remain in a wait‑and‑see mode. This is slightly higher than the EMEA baseline (20%) and risks storing up late‑stage delivery and remediation challenges.

Long‑term AML compliance costs are expected to rise structurally across EMEA. Around one‑third of firms anticipate cost increases in the 10–30% range, reflecting sustained pressure rather than temporary uplift.

Ireland mirrors this trend:

• 30% of Irish firms expect AML costs to rise by 10–30%

However, Ireland diverges on resourcing impact:

• 58% of Irish firms plan to increase AML resources
• 45% expect this uplift to span multiple functions

Across EMEA, planned AML resource increases are led by payments firms (36%) and banks (35%), followed by insurance (32%) and asset and wealth management (27%). 43% of Irish firms expect AML resourcing increases to span multiple functions, signalling a distinctly enterprise‑wide impact.

Execution bottlenecks are increasingly concentrated in core AML controls. Across the EU, Customer Due Diligence (CDD) has emerged as the primary pressure point, driven by expanded data requirements and a framework perceived as overly rules‑based.

Ireland reflects and amplifies this trend:

• 53% of Irish firms consider CDD requirements overly rules‑based, versus around 40% across the EU
• 40% of Irish firms expect a ≥10% increase in operational KYC effort

Across the EU, excessive CDD data requirements are cited by 68% of insurers, 62% of banks and 56% of asset and wealth managers. Remediation is expected to be resource‑intensive, with around 60% of EU firms reallocating internal resources to close gaps.

CDD and KYC have therefore moved from regulatory design challenges to the central operational bottlenecks of AML effectiveness.

Across EMEA, technology is widely seen as a key lever for improving AML effectiveness. 61% of banks and 57% of asset and wealth managers plan to introduce new transaction monitoring technologies, while insurance firms increasingly focus on CDD onboarding enhancements.

Ireland shows strong mobilisation:

• 74% of Irish firms have launched reviews of transaction monitoring and screening frameworks

However, data transformation requirements are substantial:

• 58% of Irish firms expect significant changes or a complete overhaul of AML reporting data structures

Across EMEA, expected reporting data structure changes range from 37% of asset and wealth managers to 22% of banks, reinforcing that data quality and infrastructure remain the primary constraints on scalable AML and AI adoption.

We're here to help

As AML expectations become more complex, Irish firms need a clear view of where readiness gaps exist and how to close them in a practical, risk-based way. PwC can support you in assessing the impact of the EU AML Package, strengthening KYC and CDD processes, reviewing data and technology requirements, and building controls that are scalable, evidence-led and effective in practice. To discuss what this means for your organisation, contact us today.