On 7 April 2016, the European Commission published a roadmap (also referred to as an inception impact assessment) relating to its proposal for a Directive to amend the Fourth Money Laundering Directive ((EU) 2015/849) (MLD4).

• http://bit.ly/1UN5rAu  

Points of interest in the roadmap include the following:

1. The Financial Action Task Force (FATF) is currently examining what further actions can be taken to strengthen the fight against terrorist financing. However, this work will take time, and even if it leads to a change in the FATF standards (which is not certain) the standards would not be legally binding.
2. A targeted data collection is currently being conducted to fill a limited number of information gaps that the Commission has identified. Initial desk research has been based on MLD4 preparatory work. The Commission already has some data from card schemes, but reliable data on virtual currencies, both at the EU and national levels, remains a challenge. The roadmap lists the areas relating to which the Commission needs further information and data.
3. To collect the additional data, the Commission launched a survey, in December 2015, asking financial intelligence units (FIUs) and public authorities for policy views and data about the agreed problem areas relating to terrorism finance. Also in December 2015, the Commission launched a consultation asking affected stakeholders (including the payment industry, virtual currencies market players, and the financial services sector) about terrorist financing challenges and potential solutions. Due to “political urgencies” and against the background that the envisaged amendments are targeted, the Commission believes that a comprehensive public consultation is not needed.
4. The relevant issues will be covered, as appropriate, by extending or building on the already existing implementation plan that seeks to ensure that MLD4 is transposed into national legislation no later than 26 June 2017.
5. The five targeted amendments concern issues that were already envisaged or discussed during the EU-level negotiations on MLD4.
6. Section E of the roadmap sets out the Commission’s preliminary assessment of the expected impacts of the envisaged amendments. The assessment is based on the consultations already carried out or currently ongoing. Among other things, taking into account the fact that this initiative is limited and targeted, the Commission considers that negative economic impacts should be small and that the administrative burden will be limited.

The proposed Directive forms part of the Commission’s February 2016 action plan to strengthen the fight against terrorism

There is no mention in the roadmap of the Commission’s call on member states to bring forward the date for effective transition and entry into application of MLD4 to the fourth quarter of 2016 at the latest, which was set out in the action plan.

The Commission is expected to publish the proposed Directive to amend MLD4 by the second quarter of 2016 at the latest.