FIN.

Treasury presses on with MLD5 implementation

HMT has opened a consultation on the implementation of MLD5.  Treasury proposes a number of changes to UK law, and seeks views on its proposals in several areas. Aspects of MLD5 addressed in the consultation include:

  • what the expanded definition of “tax adviser” and the term “letting agent” should encompass;
  • how to define virtual currencies and whether the MLD5 definition is appropriate to capture exchange, security and utility tokens, and whether FCA should be the AML supervisor;
  • exemptions available in relation e-money products;
  • clarity on the use of electronic identification processes;
  • how to define a business relationship or transaction involving a high risk third country; and
  • a national register of bank account ownership.

Responses to the consultation are welcomed until 10 June 2019. MLD5 requires implementing measures to be in force by 10 January 2020.

Avatar

Emma Radmore