By the time the industry got to grips with the overhauls presented by the Fourth Anti-Money Laundering Directive (AMLD IV), proposals for revision had already started to seep through. We are now facing a draft Fifth Anti-Money Laundering Directive (AMLD V), with tighter transposition deadlines, enhanced controls around beneficial ownership structures, and stricter measures in connection with virtual currencies.

This uncertainty is causing major headaches to subject persons as they consider the impact of these changes and contemplate whether to await formal updates from the EU or otherwise kick-start implementation, particularly in light of the tentative early transposition date which is still lingering in the background. The updated procedure file for the AMLD V should therefore provide a breathing space for subject persons; the AMLD V is now scheduled to be voted on the European Parliament's Economic and Monetary Affairs Committee on 25 January 2017 before being put to a wider vote at the European Parliament, which means that the transposition date of 1 January 2017 being proposed by the European Commission is no longer officially on the table.