Mark your calendars – 26 June 2017 will be EU AML Day.

Regulatory Sandbox photo

(The below is a high level review of certain potential issues and is not to be relied upon in any definitive manner nor as legal and/or regulatory advice.)

Anti-money laundering and counter terrorism financing laws continue to evolve in the EU and this is highlighted by the following laws being published in the EU Official Journal on 5 June 2015:


Why should 26 June 2017 be known as EU AML Day?

WTR2 applies from 26 June 2017 (Reg 27) and 4MLD is to also be transposed into national Member State law by this date (Art. 67).

Why is 26 June 2017 noteworthy?

On this date, both the 4MLD and WTR2 will likely require a change to the compliance operations of the numerous entities within their scope. There is an allowance of approx 2 years from the EU Official Journal publication date – but as compliance teams in many businesses know – booking resources can be a time consuming and challenging process. Many will need this time to implement any necessary changes – the countdown is now formally underway.

What changes are required for electronic money issuers?

Both the 4MLD and WTR2 are relevant to electronic money issuers and in some key aspects change the way the obligations of the laws they supersede apply. Please click on the relevant links which follow for a high level examination of the key changes that may apply to e-money issuers under the 4MLD and WTR2.

Leave a Reply

Your email address will not be published. Required fields are marked *