The Fourth European Union Anti-Money Laundering Directive (4AMLD) has already been supplanted by 5AMLD—amended text addressing threats that have emerged in the period between the adoption and implementation of 4AMLD. As it stands, the agreed 4AMLD text and effective date will remain, but financial institutions should anticipate additional regulatory changes from 5AMLD shortly thereafter. 5AMLD has proved to be more controversial than 4AMLD, particularly with prepaid cards and virtual currencies being more tightly regulated and uncertainty regarding the implementation of centralized registers.
This article outlines the five main requirements proposed by 5AMLD that affect financial institutions: virtual currencies, identifying prepaid card owners, beneficial ownership registers, enhanced information sharing and high-risk third countries.