10 years after the Third EU Anti-Money Laundering (ML) Directive comes the Fourth!
Is life about to become easier and less bureaucratic? I doubt it!
Also bear in mind ongoing criticism from our professional bodies, and suggestions that possibly, just possibly the profession isn't carrying out its current role particularly well - see for example:
- the 1st topic in the recent ICAEW QAD Report Practice Assurance Essentials 2015; and
- the ICAEW Anti-ML Benchmarking Survey.
The new Directive passed into European law on 26 June 2015 and we have two years from that date to implement it. The most likely outcome will be new ML Regulations (say in 2016?) and then new guidance for the Accountancy Profession.
Until a consultation is carried out, which could be this autumn, it is not completely clear what changes we will face but there are likely to be a number.
Among other areas, it is anticipated that the amount of cash that can be received in a high value transaction for the sale of goods will be lowered and that additional gambling operators may be brought into the anti-ML net. Far more than just this is likely.
In one respect the UK has already set about complying with some aspects of the new rules, for example, in the need to create a central register of ultimate beneficial owners, which we reported on in an earlier blog as having been implemented in the Small Business Enterprise and Employment Act.
We will publish a further Blog when the likely timeframe and implications become clearer. In the meantime we do all need to ask ourselves - are our present policies and procedures working adequately?
Because if we don't our professional bodies will!