While certain sections of 5MLD have already been implemented in the U.K., changes required by 5MLD in respect of the registration of the beneficial ownership of trusts have not yet come into force. HM Treasury and HM Revenue and Customs are now jointly consulting on this aspect of the regime.
In this paper, the FMLC explores the ways in which regulators and legislators have attempted to grapple with the many varieties of virtual currencies and in particular those which have arguably come to function as money for legal purposes. The definition of “virtual currencies” in the E.U.’s Fifth Money Laundering
Directive (EU) 2018/843 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the “Fifth Anti-Money Laundering Directive” or “5MLD”) expands […]