Treasury is consulting on implementing MLD4. It plans to repeal the current MLRs and Fund Transfer Regulations in favour of one piece of secondary legislation. We have produced a more detailed briefing on the paper. The consultation asks several questions, many on firms’ experience of complying with AML legislation and the costs of doing so. The paper covers only the Directive as adopted and does not discuss the European Commission’s proposals for amendment (some of which Treasury does not support). It wants comments by 10 November, but does not say when it hopes to publish the final legislation, which must be in force by 26 June 2017. To discuss MLD4’s effects on your policies and procedures, please contact Andrew Barber or Emma Radmore
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