Anti-money laundering: Introduction of new infringement procedures


On 2 July 2020, the European Commission sued Austria, Belgium and the Netherlands before the Court of Justice of the European Union, requesting financial penalties for failure to fully incorporate the 4th Anti-Money Laundering Directive into their national laws.

All Member States were required to implement the rules of the 4th Anti-Money Laundering Directive by 26 June 2017 at the latest, while the 5th Anti-Money Laundering Directive is already in force since 10 January 2020.
The transposition gaps have to do with fundamental aspects of the anti-money laundering framework, such as legislation on betting and gambling (Austria), mechanisms for exchanging documents and information between financial intelligence units (Belgium), and disclosures to be made on beneficial owners of companies and other legal entities (Netherlands).

At present, infringement proceedings have been brought against eight Member States for incomplete transposition: three had received reasoned opinions, while the Commission had already brought two others before the Court, now followed by the aforementioned three Member States.

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