The Commission has published an inception impact assessment on its proposal for a directive to amend the fourth money laundering directive (MLD4). The assessment summarises the problems with the current framework as being:

  • different approaches between Member States towards high-risk countries create weak spots which can be exploited;
  • the use of virtual currencies is more difficult to trace;
  • anonymous prepaid cards can be used by terrorists to finance part of their logistics;
  • divergent interpretations of international standards hampers their good functioning; and
  • delayed access to information by financial intelligence units on the identity of holders of bank and payment accounts hampers the detection of transfers of funds relating to terrorism.

It is these key concerns which the proposed directive is intended to address by reinforcing the current framework. (Source: Commission roadmap for MLD4 amendments)