European Commission Announces Action Plan Against Terrorism Financing and Changes to the Fourth AML Directive

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On February 2, the European Commission (EC) announced and presented an action plan (Action Plan) against terrorism financing, which includes amendments to the fourth Anti-Money Laundering (AML) Directive that went into effect in June 2015.

The EC’s Action Plan aims to: (1) trace terrorists through financial movements and prevent them from moving funds or other assets; and (2) disrupt the sources of revenue used by terrorist organizations, by targeting their capacity to raise funds.

The EC aims to complete all actions under the Action Plan by the end of 2017.

Proposed amendments to the fourth AML Directive include:

  • inserting a list of compulsory checks (due diligence measures) for financial institutions to carry out, to target countries identified as having strategic deficiencies in their national anti-money laundering and terrorist financing regimes;
  • widening the scope of information accessible by the financial intelligence units (FIUs);
  • centralizing national bank and payment registers or retrieval systems in all member states to give the FIU’s easier and faster access to information on the holders of bank and payment accounts;
  • bringing virtual currency exchange platforms within scope; and
  • lowering thresholds for identification and widening customer verification requirements in relation to “anonymous pre-paid instruments,” such as pre-paid cards, in addition to criminalizing money laundering and creating a common definition of money laundering offenses and sanctions across the European Union (among other changes).

The EC also has called on EU member states to commit to implementing the fourth AML Directive by the end of 2016 (rather than by June 2017).

A copy of the EC’s announcement can be found here.

A copy of the fourth AML Directive can be found here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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