Treasury has submitted the UK’s comments to the European Commission’s report of April 2012 on the application of the 3rd Money Laundering Directive (MLD3). It says the UK Government's view is that gaps in Europe's AML and CFT defences do not stem from national discretions and minimum harmonisation legislation, but from uncertainty over some of the key provisions in MLD3. It supports a stronger emphasis on the risk-based approach and does not believe it is appropriate for any parts of MLD3 to be transposed into a Regulation. The response includes the Government's views on several elements of MLD3 that would benefit from clarification or greater recognition of the risk-based approach, including enhanced due diligence, beneficial owners and politically exposed persons. (Source: Treasury Responds on MLD 3)