MLD4 – proposed amendments
News    ·   06-07-2016

AUTHOR: Diane Bugeja

On the 5 July 2016, the European Commission adopted a proposal to amend the Fourth Money Laundering Directive (“MLD4”). This proposal is the first initiative taken by the Commission to implement the Action Plan for strengthening the fight against terrorist financing of February 2016. The salient amendments to the MLD4 that are being proposed include the following:

  • the adding of virtual currency exchange platforms and custodian wallet providers to the list of obliged entities;
  • the lowering of thresholds for non-reloadable pre-paid payment instruments to which CDD measures apply to €150 from €250;
  • suppressing the CDD exemption for online use of prepaid cards;
  • the granting of new powers to FIUs to request information from any obliged entity;
  • the requirement for Member States to set up automated centralized mechanisms so as to swiftly identify holders of bank and payment accounts;
  • the harmonization of the EU’s approach towards high-risk third countries;
  • allowing public access to information on the ultimately beneficial owners of companies and trusts engaged in commercial or business-like activities as well as allowing access to such information on a legitimate-interest basis for family or charitable trusts;
  • enabling the interconnection of national central registers; and
  • encouraging Member States to bring the transposition of the MLD4 into national law forward to 1 January 2017

The proposed update of the legal rules will be adopted by the European Parliament and the Council of Ministers under the ordinary legislative procedure. 

The above constitutes a general overview. For further details, please access the links provided or contact Diane Bugeja at

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