Key takeaways:

• The Fourth Anti-Money Laundering Directive introduces an enhanced risk-based approach, which significantly increases the requirement on entities to identify and assess the risks of money laundering and terrorist financing in every individual business relationship and transaction.
• In addition, the Directive increases the transparency requirements surrounding beneficial ownership, by requiring companies to maintain detailed records evidencing such ownership and making them available on a central register. The Directive also removes the distinction between “external” and “internal” politically exposed persons, meaning that a higher degree of caution and diligence will be required even when dealing with domestic PEPs.
• The Directive introduces increased focus on senior management who will have to ensure that they are adequately trained and prepared to meet the Directive’s requirements.