In the latest newsletter the Council of Bars and Law Societies of Europe (CCBE) pays attention to the 4th Anti-Money Laundering Directive (AMLD4). The CCBE believes European legislators are moving away from the original objectives of AML legislation:
Revisions to the 4th Anti-Money Laundering Directive
The CCBE is following the legislative developments regarding the proposed revision of the 4th AML Directive. The CCBE submitted a response to the proposal which is available on the CCBE website. The CCBE believes that the objective has shifted away from fighting terrorism and towards strengthening measures to prevent tax avoidance (which is legal) and tax evasion (which is illegal). We observe that most of the proposed amendments do not relate to money laundering or terrorist financing, but have tax avoidance and tax evasion in mind. The CCBE is also concerned with various proposals which depart from internationals standards on a range of areas, proposed changes regarding the powers of the Financial Intelligence Units and requirements on trustees to disclose details of trust beneficiaries to central registries administered by each member state’s government.
Supra-national risk assessment (SNRA)
The CCBE is also following developments regarding the work on the EU supra- national risk assessment (SNRA). The
Commission will be making recommendations in 2017.