MLD5—key provisions for financial services firms—one minute guide

The following Financial Services practice note provides comprehensive and up to date legal information covering:

  • MLD5—key provisions for financial services firms—one minute guide
  • Adoption of MLD5 and implementation in the UK
  • UK implementation of MLD5
  • Key provisions of MLD5
  • Designation of virtual currency platforms and custodian wallet providers as obliged entities
  • Setting lower maximum transaction limits for certain pre-paid instruments
  • Enabling FIUs to request information on ML and TF from any obliged entity
  • Central registers of payment and bank accounts and safe-deposit boxes
  • Harmonising the EU AML/CTF approach to high-risk third countries
  • Correspondent relationships
  • More...

MLD5—key provisions for financial services firms—one minute guide

Adoption of MLD5 and implementation in the UK

The Fifth Money Laundering Directive (EU) 2018/843 (MLD5), which amends the Fourth Money Laundering Directive (EU) 2015/849 (MLD4), was published in the Official Journal of the EU on 19 June 2018 and entered into force on 9 July 2018. Member States were required to transpose the new rules into national law by 10 January 2020.

MLD4 was implemented in the UK by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLRs), which entered into force on 26 June 2017. MLD5 amended certain provisions of MLD4 on 19 June 2018. Through its Action Plan, the European Commission plans to overhaul the EU legal and regulatory anti-money laundering and counter-terrorist financing framework, including repealing MLD4 (as amended by MLD5). A detailed overview of the proposed changes are set out in Practice Note: European Commission 2020 Action Plan on AML/CTF and 2021 legislative package.

This Practice Note outlines the key provisions of the Fifth Money Laundering Directive (EU) 2018/843 (MLD5) which was published in the Official Journal of the EU on 19 June 2018 and their transposition into UK law under the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 (which amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the

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