As previously reported in the Q2 2018 edition of Allen & Overy’s European White Collar Crime Report, the European Fifth Anti-Money Laundering Directive (5MLD) entered into force on 9 July 2018, with an implementation deadline of 10 January 2020 (which may include the UK, depending on the terms of the Brexit transition period) and an implementation date of 10 January 2019 for provisions relating to anonymous safe deposit boxes.

5MLD imposes additional obligations, particularly on those in the finance sector and aims to, among other things, improve enforcement of 4MLD and to ensure tighter controls relating to high-risk third countries.

Among the changes introduced by 5MLD is the requirement to provide wider access to each Member State’s central register of beneficial ownership of corporate entities. Under 5MLD, these registers can now be accessed by the general public without the need for them to show a ‘legitimate interest’.

The table below provides an overview of how some Member States are implementing the requirement to maintain UBO Registers in their national law. Please see the following page for a summary of the implementation status of 4MLD.