The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism, known as MONEYVAL, has published its 2025 typologies report highlighting a sharp increase in crypto related crime and increasingly sophisticated sanctions evasion techniques. The report offers detailed insight into how criminal networks are adapting to evolving regulatory frameworks and exploiting digital financial infrastructure across jurisdictions.
For businesses operating in Ireland or considering establishing operations here, the report is particularly relevant. Ireland is an internationally connected financial centre and EU member state with strong regulatory alignment. As global standards tighten, companies operating within Irish structures must ensure that their compliance systems are robust, proportionate and capable of withstanding heightened scrutiny.
Crypto Assets and the Evolution of Financial Crime
Crypto assets continue to create both opportunity and complexity. While digital assets and blockchain technology have driven innovation in payments, fintech and decentralised finance, they have also introduced new vulnerabilities that criminals can exploit.
MONEYVAL highlights several emerging risk patterns:
- Use of decentralised finance platforms to obscure transactional flows
- Deployment of privacy enhancing technologies that complicate traceability
- Cross border layering of funds through multiple virtual asset service providers
- Exploitation of inconsistent supervision standards across jurisdictions
The decentralised nature of certain crypto ecosystems creates enforcement challenges. Criminal actors are leveraging peer to peer transfers, non custodial wallets and token mixing techniques to fragment financial trails. This increases the burden on regulated entities to enhance monitoring capabilities and invest in technological tools capable of analysing blockchain data effectively.
For Irish regulated firms, including virtual asset service providers, payment institutions and fund structures with digital asset exposure, this signals a clear direction of travel. Supervisory authorities are likely to expect demonstrable understanding of crypto related risk and tailored mitigation strategies rather than generic AML policies.
Sanctions Evasion and Complex Corporate Structures
The report also focuses heavily on sanctions evasion. As geopolitical tensions persist globally, sanctions frameworks have expanded significantly. Criminal networks and sanctioned entities are responding with increasingly complex structuring arrangements.
Common typologies include:
- Use of shell companies across multiple jurisdictions
- Nominee directors and shareholders masking ultimate beneficial ownership
- Trade based money laundering techniques
- Misuse of professional intermediaries
Ireland’s corporate transparency framework, including beneficial ownership registers and Central Bank supervision, positions the jurisdiction as credible and compliant. However, companies operating in international trade, financial services and cross border corporate structuring must ensure that their due diligence processes are capable of identifying indirect exposure to sanctioned parties.
Governance Implications for Boards
One of the key takeaways from the 2025 report is that financial crime risk is no longer purely an operational issue. It is a governance issue. Boards and senior management teams are expected to actively oversee AML and sanctions compliance, allocate adequate resources and ensure effective reporting lines.
Regulators increasingly assess whether:
- Risk assessments are regularly updated
- Transaction monitoring systems are calibrated to emerging threats
- Staff receive targeted training
- Internal audit and independent reviews are conducted
For companies establishing in Ireland, embedding strong governance structures from day one is significantly easier than retrofitting compliance frameworks after regulatory engagement.
Strategic Considerations for Expanding Businesses
Businesses considering Ireland as a base for EU operations benefit from a stable and well regulated environment. However, entry into the Irish market requires preparation. Financial crime compliance expectations are high, particularly in sectors such as fintech, funds, payments and cross border advisory services.
Proactive steps include:
- Conducting a jurisdiction specific AML risk assessment
- Designing policies aligned with Irish and EU regulatory expectations
- Ensuring clarity around beneficial ownership and control structures
- Implementing board level oversight mechanisms
At City Trust, we work closely with international clients to design regulatory compliant structures that align with both commercial objectives and supervisory expectations. As enforcement cooperation increases globally, businesses that demonstrate transparency and strong governance will be best positioned for sustainable growth in Ireland and across Europe.
