Finance Monthly November 2019 Edition

18 www.finance-monthly.com FINANCE & BUSINESS - ANTI-MONEY LAUNDERING 4AMLD originally came into effect through local laws in the UK and other EEA (European Economic Area) jurisdictions in June 2017. This Directive and related legislation brought about some of the most comprehensive and high impact changes to the AML approach that the “obliged entities” have yet to experience. In May 2019, the European Commission (EC) mandated that obliged European home-based regulated entities must conduct a full assessment of every non-EEA country which they have branches or subsidiaries based, by 3rd September. This includes the following: • Performing a detailed country-by country assessment of whether the local regulatory requirements for these non EEA jurisdictions fall below the Group EEA requisite standards; meaning that less strict requirements may be applied (including for suspicious transaction identifying and data sharing). • Having a written AML/CTF risk assessment in each third country, including obtaining senior management approval at Group level for the assessment. In September 2019, wide-ranging changes came into effect relating to the 4th Anti-Money Laundering Directive (4AMLD). Banks, financial and credit institutions (including FinTechs and MSBs) as well as other “obliged entities” must be prepared to take urgent action if they haven’t already. 4AMLD CHANGES START TO BITE WITH 5AMLD LESS THAN SIX MONTHS AWAY Chris Mangioni Associate Director - Protiviti www.protiviti.com