The European Commission has published a speech (Speech) by Věra Jourová, the European Commissioner for Justice, Consumers and Gender Equality, delivered on 25 June 2018, in which she gives a damning assessment of the implementation of the fourth Anti-Money Laundering Directive (AMLD4), describing it as “weak and unsatisfactory”.
AMLD4 was required to be transposed by Member States in the EU by 26 June 2017, but Ms Jourová revealed that the Commission had opened infringement procedures against 20 Member States for non-transposition. This goes further than the 17 countries it was reported were written to last year over alleged partial or complete failure to implement the provisions. Ms Jourová also stated that the Commission were beginning the process of scrutinising the content of notified legislation for compliance with the requirements of AMLD4.
The Speech also touched on the detailed methodology for assessing third countries, and the Commission is working towards prioritising those countries which need to be assessed by the end of the year. The Commission intends to present its first Delegated Regulation updating the list of high-risk third countries by the end of this year. The Speech noted that the Commission estimates to have over 85% of all countries in scope of the EU assessment covered by 2022.
Michael McKee has over 20 years’ experience in the financial services sector having practised at major international law firms in London.