A number of updates and reminders have been published regarding the EU 5th ML Directive.

Irish law firm, Dillon Eustace on 13th June explained that the Directive was drafted partly as a response to the terrorist attacks that shook Europe in 2015 and 2016 in Paris and Brussels, along with the Panama Papers leak which revealed the chink in the armour of the EU fight against terrorist financing, and intends to increase transparency in financial transactions by introducing some radical reforms, which the article lists, including centralised beneficial ownership registers; art dealers, tax advisors, letting agents and crypto currency exchanges will be required to verify the identity of clients and to perform CDD/KYC; and the transaction threshold for requiring customer identification when using general purpose anonymous prepaid cards is to be reduced from €250 to €150.  It says that the Directive will be published shortly in the EU Official Journal and has an estimated deadline for transposition before the end of 2019.

Arendt and Medernach in Luxembourg also issued an update on 12th June. This noted enhanced powers for supervisory authorities and FIU; extension of AML controls to virtual currency and fiat current exchange service providers; a requirement to establish centralised automated systems to allow for identification of holders of bank and payment accounts and safety deposit boxes with access for FIU

Bright Line Law also issued a briefing on 25th May, looking forward to the new Directive.

The draft Directive may be found at –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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