AML4D – The Fourth Anti Money Laundering Directive

What is Anti Money Laundering (AML)?

Anti-Money Laundering is quite simply the prevention of Money Laundering, a process of making illegally gained goods appear legal. The subject of AML is quite broad and regulations differ from one jurisdiction to another.

Financial institutions have an important role to play in the identification of potential money laundering activity and reporting obligations to respective financial intelligence units within their country.

What is the Fourth AML Directive (AMLD4) ?

The fourth version of the Anti-Money Laundering Directive (EU 2015/849) was officially adopted by the European Parliament on 20th May 2015. Originally member states had to ensure that AML4D was translated to national law by 26th June 2017. However, as a response to terrorist attacks in Europe throughout 2015/2016 and the leak of the Panama papers the European Parliament published proposals to amend AMLD4. One of the amendments was to bring the transposition date forward to 1st January 2017, some 6 months earlier than the previous date.

The purpose of the renewed directive is to not only update and keep current with technologies, but to remove any ambiguities in the previous directives. It also aims to improve consistency of AML and counter-terrorist financing (CTF) rules across all EU member states.

AMLD4 also considers recommendations from the Financial Action Task Force (FATF) that were introduced in 2012, something in which Guernsey meets 48/49 key criteria – and is the market leader due to its impeccably high standards in regulation & compliance.

What are the objectives of AMLD4?

There are two, clear objectives for AMLD4. These are:

  1. Prevent the movement of funds and identify terrorist funding
  2. Disrupt sources of revenue for terrorist organisations

This is made achievable with modifications from the previous directives in relation to:

  • A ‘risk based approach’ being a primary focus
  • Ongoing monitoring & reporting requirements
  • Customer Due Diligence (CDD) checks
  • Coverage of the gambling sector and tax crimes
  • Beneficial ownership registers
  • Various other enhancements of the finer points to the directive


Need advice?

Midshore can assist you in a number of ways with your AML / CFT commitments. We can provide CDD checks, compliance checks or act as the role of compliance officer to your business.

On a consultancy level, we are able to completely overhaul your current systems and processes and project manage any changes you may require. Further to this, Midshore can offer training both in-house or at our training facility as well as competence checks for your staff members.

Please contact us to discuss your needs.