The following Financial Services practice note provides comprehensive and up to date legal information covering:
Brexit: As of exit day (31 January 2020), the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an implementation period, during which it continues to be subject to EU law. This has an impact on this Practice Note.
This Practice Note provides a guide to the elements of the UK anti-money laundering (AML) and counter-terrorist financing (CFT) regulatory regime as it applies to regulated financial services firms. It also provides a summary of the impact of Brexit on the UK’s AML/CTF regime.
The principal EU legislative measures on anti-money laundering (AML) and counter-terrorist financing (CTF) are:
the Fourth Anti-Money Laundering Directive (EU) 2015/849 (MLD4), which became effective on 25 June 2015—the final date for implementation of MLD4 by Member States was 26 June 2017, and
the Second Wire Transfer Regulation (EU) 2015/847 (WTR2), which has direct effect within the EEA from 26 June 2019
MLD4 ensured alignment with the recommendations of the Financial Action Task Force (FATF), the global AML and CTF regulation-setting body. Shortly after the finalisation of MLD4, terrorist attacks in Paris and Belgium and the revelations in the Panama Papers prompted amendments to MLD4 which, among other provisions, extended AML obligations to virtual currency providers. These amendments were contained in the Fifth Money Laundering
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