On 27 June 2017, the Joint Committee of the three European Supervisory Authorities (“The ESAs”) – namely the European Banking Authority, the European Insurance and Occupational Pensions Authority and the European Securities and Markets authorities – has issued Joint Final Guidelines (the “Guidelines”) under the 4th Anti-Money Laundering Directive (“4AMLD”). It focuses on customer due […]

What is the background to the Directive? 1. As AML and terrorist financing typologies have evolved, the underlying regulatory landscape also needed to be adapted. 2. One of the main drivers for the Directive was the issue of updated financial crime/AML recommendations by the FATF in February 2012. 3. The European Commission then engaged Deloitte […]

The Directive implements five key changes: 1. Scope a. It has increased in scope. The requirement for certain entities to carry out CDD has increased (e.g. from just casinos across the entire gambling sector and for high value goods traders). 2. Risk-based approach a. It increases the emphasis on a risk-based approach (which has already […]

EU parliament votes on fourth AML directive and regulation On 20 May 2015, the European Parliament voted on new EU anti-money laundering (AML) rules, namely the Fourth AML Directive (AMLD) and a new Regulation on information accompanying transfer of funds (AMLR). The adopted measures replace the existing AML Directive and Regulation and have the primary […]

Beneficial owners AND third-parties AND a Four Step Due Diligence ProcessThe European Commission has been working on updating its nine-year-old Third E.U. Anti-Money Laundering (AML) Directive to accommodate new international standards and to address previous shortcomings. Earlier this year, the E.U. Parliament approved new draft legislation, bringing the Fourth AML Directive one step closer to […]