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On 20 July 2021, the European Commission (the “Commission”) announced a package of four legislative proposals (the “Package”) to strengthen its anti-money laundering and countering the financing of terrorism (“AML/CFT”) rules (see the full press release here). The four proposals consist of:

  • a proposal for a new Regulation establishing a new EU AML/CFT authority;
  • a proposal for a new Regulation on AML/CFT, containing directly applicable rules, including in the areas of Customer Due Diligence and Beneficial Ownership;
  • a proposal for a Sixth Money Laundering Directive and repeal of the existing Fourth Money Laundering Directive as amended by the Fifth Money Laundering Directive (Directive 2015/849/EU); and
  • a proposal to recast the 2015 Regulation on the Transfer of Funds to introduce new requirements relating to the transfer of crypto-assets (Regulation 2015/845/EU).

The texts of the four proposals were published on the Commission's website on the same day of the press release (please find the full texts here), and were followed on 22 July by the publication of unrelated UK consultations on the UK AML/CTF regime. Further analysis of the detailed practical changes that are likely to result from these new proposals will follow in due course, but in this initial briefing we will provide a brief overview of the background to the Package and set out three key consequences of the legislative proposals.

The full briefing is available here.

 

Susannah Cogman photo

Susannah Cogman

Partner, London

Susannah Cogman
Elizabeth Head photo

Elizabeth Head

Of Counsel, London

Elizabeth Head

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Susannah Cogman photo

Susannah Cogman

Partner, London

Susannah Cogman
Elizabeth Head photo

Elizabeth Head

Of Counsel, London

Elizabeth Head
Susannah Cogman Elizabeth Head