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The fourth EU anti-money laundering directive

The final version of the fourth EU anti-money laundering directive was enacted in June 2015. The purpose of the directive is to remove any ambiguities in the previous legislation and improve consistency of anti-money laundering (AML) and counter terrorist financing (CTF) rules across all EU member states.

Overview

The fourth EU anti-money laundering directive takes into account the latest recommendations of the Financial Action Task Force (“FATF”) from 2012. The directive was finalised and adopted at a European level in June 2015 giving member states until June 2017 to transpose the directive into national legislation.

The new directive outlines a number of modifications to the third EU anti-money laundering directive, and has been welcomed overall by the industry. The primary modifications relate to the areas of:

  • Risk-based approach
  • Ongoing monitoring
  • Beneficial ownership
  • Customer due diligence (CDD)
  • Politically exposed persons (PEPs)
  • Third party equivalence
  • Policies and procedures – Data protection
  • Record keeping
  • Definition of “Senior Management”
  • Financial intelligence unit
The fourth EU anti-money laundering directive (852kb)
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