UK opens consultation on the transposition of the Fifth Money Laundering Directive

On 15 April 2019, Her Majesty’s Revenue & Customs in the United Kingdom (“HMRC”) published a consultation document seeking views on the transposition of the Fifth Money Laundering Directive (Link). This consultation, inter alia, invites views and evidence on the steps that the government proposes to take to meet the United Kingdom’s (“UK”) obligation to transpose the directive (EU) 2018/843 (5MLD) into national law.

5MLD, among other things, requires obliged entities to apply customer due diligence when they have any legal duty in a calendar year to contact the customer for reviewing their relevant beneficial ownership information, or where the obliged entity has this duty under the EU Directive on Administrative Cooperation in the Field of Taxation (“DAC2”), which was transposed into UK law via the International Tax Compliance regulations, placing a common reporting standard (“CRS”) reporting obligation on UK financial institutions.

The closing date for comments to be submitted is 10 June 2019.

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