I am going to share with you my view on the 4th EU Directive’ in just 90 seconds.
- The Directive was finally adopted on 20 May 2015
- And reflects the 40 recommendations that were published by FATF in 2012 and these repeal the 3RD EU Directive.
The changes that you and your customers need to know include:
- Beneficial ownership of legal persons, including trusts, must now be registered and made available to all ‘interested’ parties to support CDD.
- PEP definition now includes domestic PEPs and members of international organisations, such as UN, IMF and dare I say it FIFA? But PEPS no longer have to be approved by the board of directors. Good news for the over worked Board!
- Housing letting agents have been included as obliged entities as concerns remain about the misuse of the housing market.
- Persons trading in goods should now be covered if they handle cash transactions of EUR 10 000 or more.
- Gambling sector services has been extended beyond casinos
- A new list of high-risk jurisdictions will be provided by the Commission but details of the ‘equivalence list’ appear to have been lost
- Tax crimes have been added to the definition of ‘criminal activity’
- Customer records may now be held for up to ten year, but no more than this!
What happens next?
- Member states will be required to adopt and ratify the changes on a national level.
- This may well take until late 2016 but several countries are moving forward with their own legal initiative so why not act today and take the next steps and close those doors to the big bad wolf outside!!
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