Issue 478 (Week ending 19/10/2021)

The Anti-Money Laundering Directive (AMLD) is a set of regulatory requirements issued by the European Union containing rules to combat money laundering and terrorist financing by EU member states. There have been many amendments to the directive, the most recent being AMLD5 which was required to be adopted by all EU member states by Jan 10th 2020.

What did AMLD4 Introduce?

• UBO:The requirement on all corporate and legal entities to record their Beneficial Owner data with the new Register of Business Ownership. This was to boost transparency surrounding the people who ultimately hold the power and receive the benefits from companies
• PEPs: AMLD4 expanded the definition of who can be a PEP to the families of PEPs and checks are now required on all PEPs for at least 18 months after they have ceased to be so, up from 12 months.
• Risk Based Approach: A risk based approach much be adopted i.e. Each customer's risk level must be determined and then the relevant controls put in place to manage that level of risk.

What did AMLD4 Introduce?

Like AMLD 4 was passed before it had to be adopted (2017) but all member states were obliged to operate under its rules by Jan 2020. It included:

• UBO:AMLD5 increased the transparency of UBO and now UBO national registers must be inter-connected at an EU level in order to facilitate cooperation and the exchange of information between member-state authorities. This is to make UBO information more publically available within the EU. In short, UBO in AMLD5 is now even more important and serious in the AML Directive.
• PEPs:5AMLD requires EU member states to compile and publicly release a functional PEP list made up of prominent politically exposed public functions. Functional PEPs are rare so this new EU published list will feature the positions that are considered politically exposed but will not name the person fulfilling the function. Simply, PEPs have become a more important aspect of the Directive.
• Obliged EntitiesExpanded the scope of who is considered an obliged entity and must be included in AML Due Diligence.

Who are Obliged Entities?

Obliged entities are those who must perform due diligence on their customers in order to lawfully operate under the EU AML Directive. These entities include but may not be limited to:

• Credit institutions & Financial institutions
• Auditors, accountants and tax advisors
• Notaries and other independent legal professionals
• Trusts or company service providers
• Estate agents
• Payment Gateway Providers
• Traders in goods making or receiving payments above E10,000
• Providers of gambling services
• Life Insurance Providers

Where does CRIFVision-net come in?

Performing due diligence in accordance with the AML Directive can be confusing and time consuming. However, with CRIFVision-net you can cut the workload and cost by utilising our solutions to do all the hard work for you.

We can run single or batch checks on:

• PEPs
• Sanctions Checks
• UBOs
• Credit checks on individuals
• Credit reports & Company Documents
• & more...

Our data is Irish market focused - giving you access to the most in-depth checks on Irish entities available. While also being fully compliant and allowing for audit trails.

Get in touch today if you think we can help you with your due diligence:

Email: info.vision-net@crif.com Phone: 01 903 2660