Ultimate Beneficial Ownership and the Fourth EU AML Directive

By Jennifer Hanley-Giersch

The Fourth EU Anti-Money Laundering Directive (4AMLD) came into force in 2015 and was due to be implemented in all EU countries by June 26, 2017. However, some countries did not make the implementation deadline in June 2017 as they did not have the necessary legislation in place such as Austria, where the legislation is anticipated to take effect in January 2018. With the exception of Austria, there are 16 countries that failed to meet the implementation deadline: Netherlands, Portugal, Romania, Slovakia, Latvia, Malta, Bulgaria, Cyprus, Croatia, Poland, Ireland, Lithuania, Greece, Estonia, Finland and Luxembourg. While some member states are late in the transposing procedure and are still conducting public consultations, some countries (e.g., Portugal, Latvia, Lithuania, Croatia and Luxembourg) have since implemented the directive, whilst other countries seem inclined to wait for the amendments of the 4AMLD (often referred to as the 5AMLD) which are currently still under negotiation.

The following article sets out the current status of implementation of the 4AMLD and the launch of the ultimate beneficial ownership registry across the 27 EU member states as of October 2017.


To read the full article, published on ACAMS Today, please click here.