New EU Measures Against Money Laundering and Terrorist Financing

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Treliant Takeaway:

Treliant’s highly experienced team of global financial crimes subject matter experts stand ready to assist our clients in updating their BSA/AML programs, including the design and development of updated policies, procedures, and processes to address increased duties and requirements regarding identification of their customers’ identities, including beneficial owners, and dissemination of that data to a to-be-developed central register/database.


On 28 March 2023, the European Parliament announced new EU measures to fight money laundering and terrorist financing.  The relevant committees (Economic and Monetary Affairs and Civil Liberties, Justice and Home Affairs) adopted their position on three new pieces of draft legislation:

  • The EU “single rulebook” (regulation)[1] – contains provisions on conducting due diligence on customers, transparency of beneficial owners, the use of anonymous instruments (e.g., crypto-assets), and new types of entities such as crowdfunding platforms.
  • The 6th Anti-Money Laundering (directive)[2] – includes provision on supervision and national Financial Intelligence Units (FIU), as well as access for relevant authorities to information such as beneficial ownership registers and assets stored in free zones.
  • Creation of the European Anti-Money Laundering Authority (“AMLA”) (regulation)[3] – to be established with supervisory and investigative powers to ensure compliance with AML/CFT requirements.

Collectively, the draft legislation covers:

  • Prevention of money laundering and terrorist financing
    • Covered institutions will be required to verify their customers’ identity, their assets, as well as the beneficial owners of the entity.
    • Cap payments received for goods or services (€7,000 for cash and €1,000 for crypto-assets) where the customer cannot be identified.
    • Elimination of the practice of citizenship by investment along with imposition of strong controls on residence by investment.
  • Requirement that each member state establish a national FIU to prevent, combat, and report ML/CFT
  • Transparency of customer identities
    • Information on Beneficial Ownership across the EU should be made available to national FIUs.
  • Beneficial Ownership registry
    • Sets some of the parameters for the register including, format, language, and retention schedule.
    • Data should be up-to-date and made available to FIUs, AMLA, competent authorities, self-regulatory bodies, and obliged entities. Providing poor or inadequate data can be sanctioned.
  • Access to Information
    • Persons with legitimate interest (e.g., journalists, reporters, civil society organizations, etc.) can apply for and be granted access to the Beneficial Ownership register.
  • AMLA to ensure consistent enforcement
    • Will monitor internal and external (to the EU) threats and directly supervise FIs, while classifying them according to their risk level.





Tyler Langenkamp

Tyler Langenkamp is a Managing Director at Treliant. He has over 25 years of experience advising clients across many industries on the development of major initiatives and compliance programs related to anti-money laundering (AML) and sanctions, risk management and mapping, bankruptcy and restructuring, as well as investigations and dispute resolution.