In the next in our series of detailed briefings on proposed changes to the EU and UK anti-money laundering and countering the financing of terrorism (“AML/CFT“) regimes, we consider the proposed changes to customer due diligence (“CDD“) measures, as set out in the EU’s recent AML reform package.

Published in July 2021, the AML reform package includes proposals for a new regulation on AML/CFT (the “Regulation“), containing directly applicable AML/CFT rules and requirements, as well as a new Sixth Money Laundering Directive (“6MLD“) (repealing the Fifth Money Laundering Directive (Directive 2015/849/EU)). The Regulation and 6MLD, together with a recast Regulation on the Transfer of Funds (Regulation 2015/845/EU), form part of the new, harmonised EU Single Rulebook that is expected to come into force by the end of 2025.

The proposed Regulation sets out a more detailed and granular set of requirements which EU-regulated entities will need to follow when undertaking CDD measures. We focus on the key clarifications and amendments to those requirements in this briefing, in particular those relating to identifying the customer’s beneficial owner, and determining the nature and extent of CDD measures.

The full briefing is available here.

 

 

Susannah Cogman
Susannah Cogman
Partner
+44 20 7466 2580
Daniel Hudson
Daniel Hudson
Partner
+44 20 7466 2470
Brian Spiro
Brian Spiro
Partner
+44 20 7466 2381
Elizabeth Head
Elizabeth Head
Of Counsel
+44 20 7466 6443
Ali Grodzki
Ali Grodzki
Associate
+44 20 7466 6329