Anti-Money Laundering for Estate Agents and Auctioneers in Ireland

Estate agents and auctioneers are covered by Ireland's anti-money laundering (AML) law. According to the Property Services Regulatory Authority (PSRA), property service providers are "designated persons" under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, because their work can expose them to money laundering. This guide sets out what the PSRA's own pages say about the duties that follow, where the pages are silent, and how an agency can organise its compliance. The law is national, so a Dublin agency and a rural auctioneer face the same rules. If your team needs a wider grounding in the statute, our guide to AML training under the Criminal Justice Act 2010 covers the training duty in more depth.

Who supervises estate agents and auctioneers?

The PSRA's anti-money laundering page for licensees (last updated 7 October 2026 when we read it) says that in 2016 the Minister for Justice and Equality prescribed the PSRA as the State Competent Authority for property services providers under Part 4 of the 2010 Act. The PSRA monitors providers and takes the measures necessary to secure their compliance, and it provides guidance on developing and implementing AML and counter-terrorist financing (CFT) policies and procedures.

The same page explains that the rules apply across the licence categories. Following an amendment signed into law on 18 March 2021, which implemented the EU's Fifth Anti-Money Laundering Directive, the page says the rules apply to category C (letting) and category D (property management) licensees as well as category A (auction of property other than land) and category B (purchase or sale of land).

The PSRA also lists the legislation it considers relevant on a separate page, last updated on 29 July 2022. That list includes the 2010 Act, the 2013 Criminal Justice Act, the 2018 and 2021 amending Acts, and the 2016 Regulations that set out the competent authority arrangements.

What the PSRA says licensees must do

The PSRA's page summarises the obligations in plain terms. It says property service providers must:

• have appropriate training and procedures to identify and report money laundering they become aware of;
• carry out business and client risk assessments for money laundering routinely;
• interpret and comply with the applicable AML legislation themselves; and
• follow the amended rules on clients from high-risk third countries and on the use of beneficial ownership registers.

The PSRA's one-page "Quick Guide" to key AML/CFT responsibilities fills in some detail. The copy we opened is the July 2022 version; the PSRA's page now lists an updated Quick Guide, so check the current one. The July 2022 version says the following.

• Policies and training. Providers need policies and procedures to detect and prevent money laundering and terrorist financing, and all staff involved in the business need ongoing training on spotting suspicious activity and what to do about it.
• Business risk assessment. A full assessment of the money laundering and terrorist financing risks to the business, identifying the controls in place, reviewed and updated as risks change.
• Client risk assessment. Each client is rated high, medium or low and the rating is recorded.
• Record keeping. AML records are kept for at least five years, even if the provider has stopped trading, and personal information on those records is deleted once the retention period ends.

When customer due diligence applies

The Quick Guide explains when customer due diligence (CDD) has to be completed. For sales, purchases, auctions or the management of multi-unit developments, it says CDD must be completed before the business relationship begins, for example before a letter of engagement is signed. For occasional transactions it gives a value of EUR 15,000 or more, with a purchaser's booking deposit as an example. For lettings, it says CDD is required where the monthly rent is EUR 10,000 or more. It adds that CDD must always be carried out where money laundering or terrorist financing is suspected, whatever the service or amount.

The statute points the same way on lettings. The consolidated version of section 25 of the 2010 Act on the Law Reform Commission's revised-acts site describes a property service provider, including one acting as an intermediary in the letting of immovable property, as a designated person in respect of transactions where the monthly rent amounts to a total of at least EUR 10,000. That consolidation shows no "updated to" date and is a reading aid, not the authoritative text, so confirm against the Irish Statute Book and the current PSRA guidance.

The PSRA page also lists checklists for occasional transactions of EUR 10,000 or more (including EUR 10,000 rent payments) and EUR 15,000 or more, together with client risk assessment and CDD checklists for individuals, companies, partnerships and trusts. Thresholds and documents can change, so use the version currently on the PSRA site rather than a figure copied into an internal procedure years ago. For the mechanics of identification and verification, see our explainer on customer due diligence and KYC.

Cash, deposits and the "Cash Origin Form"

The Quick Guide does not specify a cash threshold. The PSRA's page, however, lists a "Cash Origin Form" described as being for cash over EUR 500. The page gives no further explanation of it in the text we read, so we cannot tell you what the PSRA expects to be recorded beyond what the form itself says. A practical approach: check the PSRA's current Cash Origin Form and guidance before relying on any internal cash policy, and make sure your staff know that the safest route for deposits is to follow the written procedure rather than improvise at a viewing or an auction.

Reporting suspicious transactions

The Quick Guide says providers must examine the background and purpose of transactions that are complex, unusually large, follow unusual patterns, or have no apparent economic or lawful purpose. Suspicious transactions must be reported "as soon as possible" to both the Gardaí and the Revenue Commissioners. The PSRA page also lists a suspicious transaction reporting flyer. Our guide to suspicious transaction reports and the FIU explains the reporting route in more detail, including the practical question of who in the business should make the report.

The Quick Guide does not address tipping off, politically exposed persons (PEPs) or the appointment of a reporting officer. The PSRA page does, however, list guidelines on prominent public function PEPs as a separate document, so read that document if your clients include people in such roles. We have not summarised it because we did not open it.

The PSRA toolkit

Beyond the Quick Guide, the PSRA page lists a template AML/CFT policies and procedures document, a business risk assessment template, guidance for letting and property management agents, CDD guidance for marts, and a staff training record template. Several of these are shown as updated in September 2026. A sensible way to use them is below. These are our suggestions, not requirements.

• Our suggestion: start from the PSRA templates, then edit them so they describe how your agency really works. A template that nobody has adapted may not reflect how your agency actually works.
• Our suggestion: name one person who owns the AML file, including the risk assessment, the training record and the reports log, and give a deputy for holidays.
• Our suggestion: complete CDD at instruction stage, not at the closing table, because the Quick Guide places it before the business relationship begins.
• Our suggestion: keep a short log of training sessions with dates and attendees, matching the PSRA's training record template.

What the pages do not say

We found no penalty figures on the PSRA pages we opened, and we have not stated any. The PSRA's legislation list page does not summarise sanctions either. The PSRA's pages we read also do not set out an inspection process in the text we retrieved. If you need to know the consequences of non-compliance, read the 2010 Act as amended on the Irish Statute Book and the PSRA's current guidance rather than relying on a summary.

The PSRA page also lists the 2021 National Risk Assessment for Ireland on money laundering and terrorist financing as a resource. Because we did not open that document, we have not drawn on it. Agencies in Dublin and elsewhere may find it useful when completing their business risk assessment.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Are estate agents and auctioneers covered by Irish AML law?

Yes. The PSRA says property service providers are designated persons under the 2010 Act, and that the rules apply across licence categories A to D.

Who monitors AML compliance for estate agents?

The PSRA's page says it was prescribed in 2016 as the State Competent Authority for property services providers and monitors their compliance with Part 4 of the 2010 Act.

How long must AML records be kept?

The July 2022 Quick Guide says at least five years, including after a provider stops trading. Check the current Quick Guide for any change.

Is there a cash limit for property transactions?

The Quick Guide does not specify a cash threshold. The PSRA page lists a Cash Origin Form for cash over EUR 500, so check the PSRA's current guidance on how it should be used.

Do we need to train staff?

The PSRA says providers need appropriate training and procedures, and the Quick Guide refers to ongoing training for all staff involved in the business.

In short: use the PSRA's own templates, complete due diligence early, train everyone who touches a transaction, and check the PSRA's page for updates before each annual review.