4th Anti-Money Laundering Directive (4AMLD) came into effect on 26th of June 2017

Did you start the transition to the new regime?

EU Fourth Anti-Money Laundering Directive (4AMLD) came into force on 26 June 2017. It aims at further contributing at the fight against money laundering and terrorism financing by strengthening the existing rules and making them more consistent across EU Member States.  

The changes bring a more robust risk-based approach to improve the management of money laundering and terrorist financing risk.

Main changes include:

  • Increased focus on Risk Assessment at the supra-national (i.e. EU), national, sectoral and entity level
  • Enhanced Beneficial Owner information stored in a national central register and accessed based on “legitimate interest”
  • Individually assessed Simplified Due Diligence with banks no longer being able to apply simplified DD to pooled client accounts
  • No ‘white-listed’ jurisdictions which leads to banks taking into account the risk related to countries outside of the EU
  • Broader definition of PEPs, including domestic PEPs
  • Due Diligence thresholds lowered for cash payments
  • Tax evasion considered a predicate offence
  • Severe and public action for non-compliance (“name-and-shame” approach), including significant monetary penalties up to 10% from yearly total gross income of the financial institution and fines for individuals (“senior management”) up to MEUR 5

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