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By Paul PÉPORTÉ, Helena FINN, Céline SHARP, Allen Overy*
Although the EU already has a robust framework in place to combat money laundering and terrorism (ML/TF) financing threats, notably with the AMLD4(1), as amended by the AMLD5(2), several shortfalls were identified by the European Commission (the Commission).
In particular, the Commission identified a lack of consistent approaches to supervision of obliged entities and uneven access to information by financial intelligence units (FIUs)(3). The Commission also considers that the lack of direct applicability and granularity of the currently applicable AMLD4 resulted in a fragmented application of AML/CTF rules across the EU.
From a practical perspective, the...
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