September 21, 2017
The Fourth Anti-Money Laundering Directive (4MLD) is an enhancement of the third money laundering directive, incorporating 40 recommendations made by the Financial Action Task Force (FAFT), following its review in February 2012. The scope of the directive builds on the existing Anti Money Laundering (AML) and Counter Financing of Terrorism (CTF) framework and introduces changes, notably around beneficial ownership identification and the definition of a Politically Exposed Person (PEP).
The 4MLD implementation date was 26 June 2017 from which all firms are expected to be compliant.
The 4MLD primarily applies to the financial sector, which includes credit and financial institutions as well as natural or legal persons acting in the exercise of their professional activities (Article 2 of the Directive). It also applies to all dealers in goods making or receiving cash payments in excess of €10,000, regardless of whether payment is made in one or more linked transactions. These are referred to as obliged or regulated entities.
The 4MLD extends the scope of the AML framework. It introduces increased obligations on firms and widens its application. Key changes include: