Published: 5th February 2016

As we know the UK (and other Member States) have until 26 June 2017 to implement the Fourth Money Laundering Directive (2015/849 – “4MLD”) into national law – see the “Complyport: Fourth Money Laundering Directive” link.

A press release advises that the European Commission is:

  • Calling on Member States to commit to implement 4MLD by the end of 2016.
  • Proposing a number of amendments to 4MLD.

This rethink arises from an ‘Action Plan’ (the – separate – Annex of which summarises the proposals in tabular form) to strengthen the fight against terrorist financing which, at least in part, has been fuelled by recent terrorist attacks in the EU and beyond.

Proposed amendments to 4MLD include (but are not limited to):

  • Including a list of all compulsory checks that firms should carry out with regards to high risk third countries.
  • Bringing virtual currency platforms under the scope of 4MLD.
  • Lowering the identification threshold in respect of pre-paid cards etc.
  • Enhancing the powers of EU Financial Intelligence Units.

The Commission will present a legislative proposal in respect of all of the amendments at the latest by Q2 2016.

Elsewhere the Commission will:

  • Adopt an EU blacklist to identify high risk third countries (by Q2 2016).
  • Publish a report on a supranational assessment on money laundering and terrorist financing risks and recommendations to Member States on measures suitable to address those risks (by Q2 2017).
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