Are You Ready?

The Fourth EU Anti-Money Laundering Directive (EU 2015/849) (AMLD4) is the latest significant upgrade to the EU legislative programme in the area of anti-money laundering and counter-terrorist financing (AML/CTF). AMLD4 implements recommendations by the Financial Action Task Force (FATF) and, on some issues, expands on FATF’s requirements and provides for additional safeguards.

On 5 July 2016, in response to terrorist attacks in Europe in 2015/2016 and the leak of the Panama papers, the EU Commission published proposals (AMLD5) to amend AMLD4. The EU Council Presidency has agreed its negotiating mandate in relation to AMLD5 and has indicated that it seeks to conclude negotiations with the European Parliament by 30 June 2017.

Therefore, although the EU Commission had intended that both AMLD4 and AMLD5 would become effective simultaneously, this clearly will now not happen.

Overview of the principal AMLD4/AMLD5 amendments: