January 10th and the 5th AMLD

By the 10th of January 2020, each member state in EU must transpose the 5th Anti Money Laundering Directive (AMLD) into national legislation.

The highlights of the amendments the 5th AMLD will introduce are:
– Access to beneficial ownership information of EU based companies for the general public through a register, along an obligation to consult this register when performing due diligence in relation to Anti Money Laundering (AML)
– Virtual currency (cryptocurrency) platforms and wallet providers, shall be in scope of AML obligations
– Each EU-member state must create a list of national public offices and functions that qualify as politically exposed persons (PEP)
– Financial flows from high-risk countries will be subject to enhanced AML due diligence measures
– The thresholds for identifying purchasers of prepaid cards and for the users of e-money will be lower.

SALVUS advices that all firms make sure you already have in place strong AML policies and procedures in a company-wide approach,
– Understanding how to identify PEPs, relatives and close associates
– Having processes in place to identify all relevant parties in the transaction, including beneficial owners
– Strict record keeping and clear audit trails in place
are good starting points.

SALVUS discusses the upgraded regulatory regime of the 5th Anti-Money Laundering Directive (AMLD5) and its impact on the financial industry in an earlier article, published in May 2019.

We are ready to help your internal team perform a gap analysis and review your policies and procedures and then train key personnel as necessary. Talk to us.

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