It feels as though we’ve been waiting for the Fourth Money Laundering Directive for about a decade, doesn’t it? Well, I suppose we have, really, as the third one was adopted in 2005. But at long last we know what’s expected of us. Just to recap the three vital dates:
- 20 May 2015: final text of MLD4 is released (albeit dated 8 May 2015)
- 5 June 2015: text of MLD4 is published in the EU’s Official Journal, and includes the crystal-clear line (in Article 67) that “Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 26 June 2017”, which gives us… *drum roll please*
- 26 June 2017: the date by which all EU Member States are expected to have updated their domestic AML legislation to bring it into line with MLD4.
I’ve only just taken delivery of my 2016 diary so there’s nowhere I can write it down, but I feel sure that regulators and legislators around the world – not just in EU Member States – will be creating giant wall-charts and working backwards from that date to make sure that they have in place (their own version of) the big three changes brought in by MLD4: extension of PEP definition to include domestic as well as foreign PEPs; inclusion of tax evasion as a predicate offence for money laundering; and (the one that has been causing all the excitement) preparation of a register of beneficial ownership. On your marks…