Results of the CFE Survey on the Implementation of the 4th AML Directive


EU Member states had until 26 June 2017 to implement the 4th EU Anti-Money Directive (“AMLD”) into domestic legislation. The 4th AMLD reinforces the existing rules by introducing the following changes: reinforcing risk assessment obligation for certain obliged entities; setting transparency requirements about beneficial ownership for companies, facilitating cooperation and exchange of information between Financial intelligence units, establishing a coherent policy towards non-EU countries that have deficient anti-money laundering (“AML”) and terrorism-financing rules, and, reinforcing the sanctioning powers of competent authorities.


Tax advisers are considered obliged entities for AML purposes pursuant to Article 2 of the 4th AMLD. The AML supervisory regime is complex and the 4th AMLD poses many practical questions for tax advisers and supervisors of the AML compliance.
The questionnaire aims to gather data of the countries on the implementation status of the 4th AML Directive, in particular regarding national risk assessments, beneficial ownership registers, your supervisory obligations, if any, the national oversight regime, as well as issues that you encounter related to identification of risks and compliance in general.
The countries which responded to the questionnaire are: Austria, Belgium, Croatia, Czech Republic, Ireland, Italy, Lithuania, Luxembourg, Russia, Spain, the Netherlands and the United Kingdom.