General information
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EU
In the European Union, it has been adopted six Anti-Money Laundering directives in the time-frame of 30 years, with further reform proposals under consideration.
In the last year, the European Commission has released a specific document, a sort of action plan, as an adequate tool to combat financial crime. This has been followed with the public consultation from various industries and to inform the Member States of the proposed Anti-Money Laundering regulation.
As part of the Anti-Money Laundering Directive, which is still under the consideration and analysis of the EU Commission, is the introduction of the cash payment limit of 10,000 EUR.
These types of rules already exist in some of the Member States. In 18 from the 27 Member States, the governments have already introduced upper limits for cash payment or are in the procedure of transposing these provisions into the national legislation.
These different approaches which have been introduced through national regulation, have distorted the EU market and have opened different channels for various types of financial crimes.
The Commission has published the document open for discussion to the expert groups of the EU countries.
There are different types of barriers concerning the implementation of the AML Directive due to the delayed or incomplete introduction of the related provisions into the national legislation of some of the Member states.
The expectation is that the AML regulation on the EU level will be published in 2021 and that it would be directly applicable on the effective date.
There is still a long way to go for defining the regulation and its related publication.
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