Resources
Submission on 4th Anti-Money Laundering Directive
The Law Society made a submission regarding the ‘member state discretions’ contained in the 4th AML Directive on the Prevention of the use of the Financial System for the Purposes of Money Laundering or Terrorist Financing.
For details, see Directive (EU) 2015/849.
The submission was made in response to the public consultation issued by the Department of Justice and Equality and the Department of Finance in January 2016.
Seven issues were highlighted in the Departments’ consultation paper, with specific questions raised in relation to each issue.
The Law Society’s submission dealt with the specific issues of the beneficial ownership register (corporates) and the beneficial ownership register of trusts.
The Law Society also took the opportunity in its submission to address the issue of the treatment of solicitor client accounts under the 4th AML Directive (using the final ‘catch-all’ heading of ‘other issues’ as contained in the consultation paper).
