Fourth Anti-Money Laundering Directive Comes Into Force

3 August 2015
View Client Update

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.