Ireland adds closed-loop payments to its 30-point anti-money laundering plan for gambling, crypto and payment flows

Ireland has launched a new national framework for financial crime that puts gambling, cryptocurrency and payment flows under sharper scrutiny. For PSPs, acquirers and gambling operators, the part to watch is the planned closed-loop payment requirement: withdrawals would have to go back through the same payment account used for the deposit.

1. The measures were published on 18 June 2026 as part of a 30-point action plan alongside Ireland’s latest National Risk Assessment on Money Laundering, Terrorist Financing and Proliferation Financing. The plan was launched by Tánaiste and Minister for Finance Simon Harris and Minister for Justice, Home Affairs and Migration Jim O'Callaghan.
2. The stated aim is to tighten cooperation between government departments, law-enforcement bodies and regulators, and to improve Ireland’s response to more sophisticated financial crime. The framework is not just about gambling, but gambling is one of the areas singled out for specific action.
3. For the gambling sector, the notable items are a proposed closed-loop payment requirement, stronger oversight of machine-based casino clubs, mandatory licensing for private members’ clubs that offer gambling services, and an industry standard covering crypto-related funds. In other words: payments, club licensing and crypto all get pulled into the same compliance frame.
4. The closed-loop rule would require gambling service providers to send customer payments back to the same payment account that was used to deposit the funds. The practical effect is straightforward: if a customer deposits through one payment account, withdrawals would generally need to go back to that same account, which makes tracing flows easier and reduces the room for money to hop between unrelated payment channels.
5. According to the implementation plan, the closed-loop requirement is a specific action for the Gambling Regulatory Authority of Ireland (GRAI), with a target delivery date in the second quarter of 2027. So this is a forward-looking regulatory programme, not an immediate final rule for every operator today.

Closed-loop controls are already a familiar AML tool internationally. The UK's Gambling Commission has identified open-loop payment arrangements as a risk because funds can move between different payment methods and make the origin or destination of money harder to establish. For Irish operators, that means payment rails, exception handling and account verification logic may need to be tightened before the rule lands.