Q&As

Based on Article 3(6)(a)(ii) of the Fourth Anti-Money Laundering Directive (EU) 2015/849 (MLD4) the definition of 'beneficial owner' is extended to 'the natural person(s) who holds the position of senior managing official(s)' in case all possible means have been exhausted to identify a person under point (i) of MLD4, Art 3(6)(a). Is there any guidance on the interpretation of this new extended definition?

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Published on LexisPSL on 18/12/2017

The following Financial Services Q&A provides comprehensive and up to date legal information covering:

  • Based on Article 3(6)(a)(ii) of the Fourth Anti-Money Laundering Directive (EU) 2015/849 (MLD4) the definition of 'beneficial owner' is extended to 'the natural person(s) who holds the position of senior managing official(s)' in case all possible means have been exhausted to identify a person under point (i) of MLD4, Art 3(6)(a). Is there any guidance on the interpretation of this new extended definition?

The Fourth Money Laundering Directive, Directive (EU) 2015/849 (MLD4) is a directive and, therefore, does not have direct effect. MLD4 Directive (EU) 2015/849 has been transposed into UK law by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer)

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