European Union: Money Laundering

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Article
Sanctions Monitoring Board Issues Guidance Document On Sanctions Compliance Requirements
Malta's Sanctions Monitoring Board has issued comprehensive compliance guidelines establishing a legally binding framework for sanctions implementation. The new requirements mandate enterprise-wide risk assessments, enhanced customer due diligence extending beyond traditional beneficial ownership analysis, and robust screening protocols to identify and prevent sanctions breaches.
Malta Commercial
GA
Ganado Advocates
Article
Updates To The Companies Act (Register Of Beneficial Owners) Regulations
Malta has introduced significant amendments to its beneficial ownership regime through the Companies Act (Register of Beneficial Owners) (Amendment) Regulations, 2026, establishing a three-tier access system and new reporting requirements. Companies must now assess whether they fall within the scope of the updated regime and comply with the new Form BO4 filing obligations by January 2027, or face substantial penalties.
Malta Commercial
CP
Camilleri Preziosi Advocates
Article
Business-Wide Risk Assessment (BWRA): New Cyprus Bar Association Guidance And The 2027 AMLR Deadline
The Cyprus Bar Association has issued its first Guidelines on Business-Wide Risk Assessment (BWRA), establishing a comprehensive framework for supervised entities to identify and mitigate money laundering, terrorist financing and sanctions risks. These guidelines provide practical direction for compliance with the new EU Anti-Money Laundering Regulation ahead of its July 2027 implementation deadline, outlining methodologies for risk assessment, control evaluation and ongoing monitoring requirements.
Cyprus Government
Frangos Law
Article
Netherlands – Investment Bank Fined €8.5m For Compliance Failures, Including Sanctions
The Dutch central bank has imposed a significant financial penalty on ABN Amro for failures in its customer due diligence processes, particularly concerning high-risk clients. The investigation revealed critical gaps in the bank's ability to identify and address potential sanctions evasion involving dual-use goods and intermediaries in high-risk jurisdictions.
Netherlands Government
DM
Duane Morris LLP
Article
New Italian AML Requirement: Bank Of Italy Mandates Notification Of The AML Responsible Officer
Italy's Bank of Italy has introduced a mandatory notification requirement for the appointment of AML responsible officers, effective July 2026. Obliged entities under the Bank of Italy's supervision must now communicate appointments and changes within specific timeframes through designated procedures. This analysis provides a comprehensive Q&A format breakdown of the new requirements, communication modalities, and critical compliance deadlines that financial intermediaries must meet.
Italy Finance
AO
A&O Shearman
Article
Jenec: The Limits Of Automatic De-Risking In EU Banking Law
On 11 June 2026, the Court of Justice of the European Union (the “Court”) delivered its judgment in Case C-81/24, Jenec. The case concerned the relationship between the right of access to a payment account with basic features under Directive 2014/92/EU (the “Payment Accounts Directive”) and the AML/CFT obligations imposed on financial institutions under Directive (EU) 2015/849 (the “AML Directive”).
Cyprus Finance
EN
Elias Neocleous & Co LLC
Article
Ireland’s AML/CFT Action Plan: 2026 – 2027
Ireland's Department of Finance has released its third National Risk Assessment on Money Laundering, Terrorist Financing and Proliferation Financing, identifying very significant risks in retail banking, digital banking, crypto-assets, and payment institutions. The assessment is accompanied by a comprehensive 30-Point Action Plan designed to strengthen Ireland's financial crime response framework over the next 18 months through enhanced regulatory oversight, beneficial ownership transparency, and sector-spe
Ireland Finance
AC
Arthur Cox
Article
Risk-based Approach : Key Updates
The Anti-Money Laundering Regulation (AMLR) introduces a more structured framework for risk assessment while maintaining the Risk-Based Approach at its core. Enhanced Due Diligence requirements now extend to high-net-worth individuals and residence-by-investment schemes, while Simplified Due Diligence faces stricter conditions. The regulation provides EU-wide clarity on politically exposed persons (PEPs) and establishes harmonised risk factors across member states.
Luxembourg Commercial
CL
CMS Luxembourg
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