-
Business Consulting
Our Consulting team guarantees quick turnarounds, lower partner-to-staff ratio than most and superior results delivered on a range of services.
-
Business Risk Services
Our Business Risk Services team deliver practical and pragmatic solutions that support clients in growing and protecting the inherent value of their businesses.
-
Corporate Finance
Our experienced Corporate Finance team has provided a range of transaction, valuation, deal advisory and restructuring services to clients for the past two decades.
-
Digital Risk
Our Digital Risk team offer advisory and consulting solutions that give our clients peace of mind, clear value for money and an enhanced ability to react to cyber attacks.
-
Digital Transformation
Our Digital Transformation team work with business leaders to deliver efficient digital strategies and operating models that provide new or enhanced capabilities.
-
Forensic Accounting
Our Forensic and Investigation Services team have targeted solutions to solve difficult challenges - making the difference between finding the truth or being left in the dark.
-
Objectives and Key Results (OKRs)
Objectives and Key Results (OKRs) is a goal setting framework that helps teams, individuals and organisations set and track measurable goals.
-
People and Change Consulting
Our People & Change Consulting team help clients adapt to the changing nature of the workforce - how they attract, retain, engage, develop, deploy and lead their people.
-
Restructuring
Grant Thornton is Ireland’s leading provider of insolvency and corporate recovery solutions.
-
Outsourced Payroll
Our outsourced payroll teams become your dedicated payroll department, aiming to process your payroll in the most cost effective and compliant manner.
-
Outsourcing
Grant Thornton's reliable and cost-effective outsourcing services help you streamline your business operations by taking care of your workload.
-
Audit and Accounting Advisory
Our Audit and Accounting Advisory team takes the headache out of multi-jurisdictional audit compliance requirements as well as technical compliance with accounting standards and legislation for clients.
-
Business Process Outsourcing
Grant Thornton’s Business Process Outsourcing (BPO) team serves the needs of rapidly growing mid-tier multinationals operating out of Ireland and other hubs through the provision of services across the full range of finance functions.
-
Flexible People Solutions
At Grant Thornton, our Financial Accounting and Advisory Services (FAAS) department have a dedicated team that help finance functions maximise efficiency.
-
Global Compliance & Reporting Solutions
Our Global Compliance & Reporting Solutions service offering covers a full suite of compliance services including financial statement preparation and related filings, dual bookkeeping, direct and indirect tax, statistical returns and payroll.
-
Global Payroll Solutions
At Grant Thornton, we meet the challenges of our clients. Our Global payroll compliance service offering is tailored to meet all your payroll requirements through a single point of contact.
-
Actuarial
Our Actuarial team provides a comprehensive range of services to our insurance clients. From regulatory support for compliance to delivering specialist expertise in insurance & reinsurance.
-
Data Analytics
Our team helps to unlock the potential of data analytics within your organisation, allowing you to be more innovative, efficient and customer-centric than ever before.
-
Digital and Fintech
Our FinTech team are experts in technology and financial services and have a long track record of helping companies achieve sustained advantage.
-
Digital Risk
Our Digital Risk team offer advisory and consulting solutions that give our clients peace of mind, clear value for money and an enhanced ability to react to cyber attacks.
-
Financial Services Audit
Our Financial Services Audit team offers expertise and knowledge along with a horizontal approach to solving clients’ problems and queries.
-
Financial Services Consulting
We work closely with clients to understand their strategy and benchmark their performance against the very best international standards.
-
Financial Services Tax
Grant Thornton Ireland has a team of over 100 tax professionals providing advice to a diverse range of clients in the Financial Services sector.
-
FS Business Risk Services
Our FS Business Risk team have real experience of the financial services sector, through working within regulatory bodies or holding leadership positions in Risk, Compliance and Internal Audit functions.
-
Grant Thornton Pensioneer Trustees Limited
The Grant Thornton Pensioneer Trustee service can offer business owners, directors and employees the opportunity to manage their own retirement choices with full transparency.
-
Pension Audit
The Grant Thornton Pension Audit team has vast experience in managing schemes and preparing annual reports on them for clients.
-
Prudential Risk
Our industry leading Prudential Risk team works with clients on a range of areas including regulatory reporting, regulatory authorisations, on-site investigations and data quality assurance.
-
Quantitative Risk
Our Quantitative Risk team members bring a wide range of experience with many of them having backgrounds in banking, investment markets, regulation, professional practice, and academia.
-
Sustainability desk
We recognise that businesses are operating at different levels of maturity when it comes to sustainability, and pride ourselves on working with our clients to develop bespoke solutions to their needs.
-
Financial Accounting and Advisory Services (FAAS)
Our Financial Accounting and Advisory Services (FAAS) team designs and implements creative solutions for organisations expanding into new markets or undertaking functional financial transformations.
-
Grant Thornton Financial Counselling
Grant Thornton Financial Counselling (GTFC) comprises a team of highly qualified professionals who offer financial advice to individuals and corporates across a range of areas including savings, investments, pension planning, and inheritance and succession planning.
-
Inheritance Planning
Our services on Inheritance Planning mirror those on Succession Planning whereby the foundations of the plan are derived from meaningful conversations with those that wish to pass on or protect their asset base.
-
Personal Tax Compliance & Planning
The Grant Thornton Personal Tax team helps clients remain compliant and up to date with all of their tax obligations whilst ensuring that they are solutions driven and manage their finances in the most tax efficient way possible.
-
Succession Planning
We have extensive experience guiding our clients successfully through the succession process. This involves advice on both the qualitative and quantitative aspects of the process. While there is a business at the core of each succession plan we advise on, it is all predicated on understanding the people and their respective wishes.
-
Company Secretarial
Grant Thornton’s Company Secretarial team contains qualified Company Secretaries. Clients are assured that they will meet all of their obligations under the Companies Acts and other relevant legislation and regulations.
-
Corporation Tax
Our Corporation Tax team is made up of more than 40 highly experienced senior partners and directors who work directly with a wide range of domestic, international, and financial services clients. We place a strong emphasis on direct service to clients and we pride ourselves on the close personal relationships we build and the deep understanding of their businesses we develop
-
Employer Solutions
Attracting and retaining key talent, managing employment costs and ensuring compliance with complex tax rules presents one of the most serious challenges today for many businesses. You need to ensure that your business complies with increasingly complex tax legislation and can adapt to updated Revenue guidance in a cost-effective way and we are here to help.
-
Financial Services Tax
The Grant Thornton team is made up of experts who are fully up to date in terms of changing and evolving tax legislation. This is combined with industry expertise and an in-depth knowledge of the evolving financial services regulatory landscape.
-
Global Mobility Services
Grant Thornton Ireland offer a different approach to managing global mobility. We have brought together specialists from our tax, global payroll, people and change and financial accounting teams across Ireland and Northern Ireland, while drawing on the knowledge and insights of our global network of over 143 offices of mobility professionals to provide you with a holistic approach to managing global mobility.
-
International Tax
We develop close relationships with clients in order to gain a deep understanding of their businesses to ensure they make the right operational decisions. The wrong decision on how a company sells into a new market or establishes a new subsidiary can have major tax implications.
-
Tax Advisory
The Grant Thornton Tax Advisory team blends commercial experience and knowledge with tax expertise to advise clients on the full range of transactions including sales, mergers, restructurings and succession planning.
-
Tax Incentives
Our Tax Incentives team help clients access vital cash funding and tax incentives to enable them to achieve their growth ambition.
-
Transfer Pricing
Our Transfer Pricing team has extensive experience across all industries. They can assist clients in overcoming challenges and deliver sector specific, sustainable solutions.
-
VAT
Grant Thornton’s team of indirect tax specialists helps a range of clients across a variety of sectors including pharmaceuticals, financial services, construction and property and food to navigate these complexities.
-
Real Estate Tax Advisory
The Irish real estate market has experienced considerable change in recent years. This has resulted in the emergence of a number of challenges for investors, but has also brought about significant opportunities. With this in mind, taxation is now more than ever one of the key factors for real estate investors when appraising investments, financing methods and development structuring.

What is the impact?
VASPs must apply for registration with the Central Bank of Ireland (CBI), and carry out required AML/CTF obligations. Note that to carry on the business of a VASP in the absence of registration, and failure to comply with AML/CTF obligations is a criminal offence.
Registration with Central Bank
The CBI will assess:
- the firm's AML/CFT policies and procedures that are effective in combatting the money laundering and terrorist financing (ML/TF) risks associated with its business model;
- the firm's management and beneficial owners are fit and proper.
Ongoing AML/CTF Obligations
- Carrying out an ML/TF risk assessment of their business;
- Undertaking customer due diligence carry out ongoing monitoring of customers and customer transactions;
- Filing 'Suspicious Transaction Reports'
- Maintaining and implementing AML/CFT policies, procedures and controls;
- Retaining appropriate records;
- Providing AML/CFT training to all staff on an ongoing basis.
Definition
Provide any of the following services relating to virtual assets:
-
exchange between virtual assets and fiat currencies
-
exchange between one or more forms of virtual assets
-
transfer of virtual assets, that is to say, to conduct a transaction on behalf of another person that moves a virtual asset from one virtual asset address or account to another
-
custodian wallet provider; and participation in, and provision of, financial services related to an issuer's offer or sale of a virtual asset or both
-
Note – ‘virtual asset’ means a digital representation of value that can be digitally traded or transferred, and can be used for payment or investment purposes, but does not include digital representations of fiat currencies, securities or other financial assets
What are the observations from the CBI on recent applications received?
The CBI has published a summary of key observations relating to recent applications received in its Anti-Money Laundering Bulletin (Issue 8/July 2022). This is to assist VASPs in strengthening their applications for authorisation.
Many applications did not contain the required information and documentation and consequently these applications could not progress to the assessment phase. As an example, some firms had submitted policies but no accompanying procedures. A number of firms submitted a copy of the firms internal risk register in place of a documented risk assessment.
“…the majority of firms that did not progress to the assessment phase had not availed of the pre-application meeting”
Expectation
An effective AML/CFT control framework is built on an appropriate ML/TF risk assessment that focuses on the specific ML/TF risks arising from the firm’s business model. This risk assessment should drive the firm’s AML/CFT control framework such that it ensures there are robust controls in place to mitigate and manage the specific risks identified through the risk assessment.
Findings
- A number of firms had not assessed or documented the ML/TF risks as they pertain to the firm’s customers and business activities. The Central Bank expects a Risk Assessment to be specific to the firm and the specific risks that pertain to that firm’s activities and customers.
- Several VASP applicant firms did not document the inherent ML/TF risks that pertain to the firm or document how, after assessing the effectiveness/ strength of the firm’s control environment, the firm had determined the residual risk rating for each of the risk factors as set out in the CJA 2010 to 2021.
- A number of firms did not consider relevant information in the National Risk Assessment, CJA 2010 to 2021 and/or guidance on risk issued by the Central Bank, when documenting the firm’s risk assessment. This included consideration of inherent risk factors, such as Nature, Scale, Complexity, Geographical Risk, Products and Services risk, etc.
Expectations
When developing AML/CFT policies, controls and procedures (“AML/CFT P&Ps”), firms should maintain a detailed documented suite of AML/CFT P&Ps, which are:
- supplemented by guidance;
- accurately reflect operational practices; and
- fully demonstrate consideration of and compliance with all legal and regulatory requirements.
Findings
- Several firms submitted AML/CFT P&Ps that did not meet the Irish legislative and regulatory requirements, in many instance referring to legislative frameworks in other jurisdictions where parent/group entities are situated. Where firms rely on group policies and procedures, these must be sufficiently detailed, applicable to the Irish entity that is applying for VASP registration and meet the Irish legislative and regulatory requirements.
- The Central Bank received several registration applications that included the firm’s policies but failed to include the firm’s procedures that document how the firm meet their legislative obligations. As detailed in the application guidance, applicant firms are required to submit AML/CFT P&P relating to Customer Due Diligence (“CDD”), Transaction Monitoring, Suspicious Transaction Reporting, Financial Sanctions, Record Keeping, Training and Assurance Testing.
Expectations
CDD involves more than just verifying the identity of a customer. Firms should collect and assess all relevant information in order to ensure that the firm:
- Knows its customers, persons purporting to act on behalf of customers and their beneficial owners, where applicable;
- Knows if its customer is a Politically Exposed Person (“PEP”);
- Understands the purpose of the account and therefore understands the expected activity; and
- Is alert to any potential ML/TF risks arising from the relationship.
Findings
- A number of applicant firms failed to demonstrate compliance with the legislative obligation to obtain information reasonably warranted by the ML/TF risk on the purpose and intended nature of the business relationship with a customer prior to the establishment of the relationship.
- The Central Bank received several registration applications where the firm failed to demonstrate how screening is conducted for PEPs for both new and existing customers. A number of firms also failed to document how PEP customers are managed including documenting requirement for Senior Management approval, the application of Enhanced Due Diligence (“EDD”) measures to PEPs and enhanced on-going monitoring measures.
- Several firms failed to document policies and procedures relating to the refresh of CDD documentation.
Expectations
The Central Bank’s expectation is that firms have an effective screening system in place, appropriate to the nature, size and risk of their business. In addition to this, firms should have clear escalation procedures in place to be followed in the event of a positive match.
Findings
Several firms failed to document the frequency of Financial Sanctions screening, how the firm screens (including what, if any, software is used) and also the steps the firm would take in the case of a Financial Sanctions hit.
Expectations
A firm can outsource certain AML/CFT Functions, but are reminded that the firm remains ultimately responsible for compliance with its obligations under CJA 2010 to 2021. It is expected that, where firms outsource AML/CFT functions, a documented agreement is in place that clearly defines the obligations of the outsource service provider. Firms should also evidence that sufficient oversight is conducted on the outsourced activity.
Findings
A number of VASP applicant firms outsource certain AML/CFT functions to group-related parties and/or non-group related parties.
- Several firms did not include their policies around outsourcing or submit their service level agreements.
- In addition to this, several firms have failed to demonstrate sufficient oversight of the outsourced activities or failed to evidence that appropriate regular assurance testing of the outsourced activities takes place.
Expectations
Individual Questionnaires should be submitted for each individual proposed to hold a PCF role as soon as practical.
Findings
A number of firms have failed to or delayed in submitting Individual Questionnaires (IQs) for each of their proposed Pre-Approval Controlled Function (PCF) role holders.
Expectations
The CBI expects a physical presence located in Ireland, and for there to be at least one employee in a senior management role located physically in Ireland.
Findings
The Central Bank may refuse an application where the applicant is so structured, or the business of the applicant is so organised, that the applicant is not capable of being regulated to the satisfaction of the Central Bank.
In conclusion, technology firms must appreciate the changing regulatory environment which brings them under the same supervisory regime as regulated financial service providers in terms of their AML/CTF obligations.
In response they must have the necessary risk culture, and risk and control frameworks in place to minimise the risk of the use of their products or services by criminals for the purposes of money laundering or terrorist financing.
“The Central Bank will only register a firm when it is satisfied that the firm can meet its AML/CFT obligations on an ongoing basis”
Why Grant Thornton
Grant Thornton’s Financial Services Risk, Consulting and Advisory teams are comprised of dedicated experts who are experienced in supporting firms with meeting the Supervisory requirements highlighted by the Central Bank.
In particular, our industry-leading Prudential Risk team understands that regulation continues to drive the strategic agenda for financial and non-financial institutions. Working together with our prudential risk specialists, we believe our skillsets combine the best of scientific knowledge with real world experience to deliver practical, actionable solutions.
We specialise in assisting clients across the financial services sector in navigating through the maze of regulation and support clients to identify regulatory obligations and work towards full compliance balanced with your business needs.