Treasury has submitted a paper on the proposals to update MLD4. Among other things, the Commission had proposed bringing virtual currencies within MLD4, reducing the threshold for CDD on non-reloadable prepaid instruments and removing the online exemption, harmonising approaches to non-compliant third countries, reducing the Beneficial Ownership criteria to 10% for passive non-financial entities and requiring Member States to establish central registers for beneficial ownership of trusts. It also wanted to accelerate implementation to 1 January 2017. The Government is concerned about the reduction in the beneficial ownership requirement and a proposal to make information about trust ownership widely available. It is also concerned about the requirement to introduce automated centralised mechanisms that will allow identification of any legal or natural person holding or controlling payment or bank accounts.
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