The European Commission has published an Action Plan to strengthen the fight against terrorist financing.  There are two main strands to this plan:

  • enhanced detection of terrorists and tracing of their financial movements; and 
  • disrupting the sources of revenue of terrorist organisations, by targeting their capacity to raise funds.

This Action Plan envisages that the implementation date of the Fourth Anti-Money Laundering Directive (MLD 4) will be brought forward to Q4 2016. The original implementation date envisaged for the MLD 4 was mid-2017. 

The Action Plan also proposes a number of specific amendments to MLD 4.  These include provisions:

  • bringing virtual currency exchange platforms within the scope of MLD 4 so that such platforms will have to apply customer due diligence controls when exchanging virtual currency for real currency;
  • setting out the specific enhanced due diligence steps which should be applied on financial flows or transactions from  countries having strategic deficiencies in their national anti-money laundering and terrorist financing regimes;
  • relating to prepaid cards focussed on reducing existing exemptions such as thresholds below which identification is not required, notably for cards used face- to- face, and requiring customer identification and verification at the time of online activation of the prepaid cards;
  • extending the scope of and the access to the information available to Financial Intelligence Units (FIU's) and facilitating their ability to access information on the holders of bank and payment accounts;

It is envisaged that the Commission will:

  • adopt an EU blacklist to identify high risk third countries with strategic deficiencies in their anti-money laundering/countering terrorism financing at the latest by Q2 2016;
  • publish a report on a supranational assessment of money laundering and terrorism financing risks and recommendations to Member States on measures suitable to address those risks by Q2 2017.