MLD5: virtually there?

Emma Radmore (+44 (0)207 788 2372, emma.radmore@wbd-uk.com) is Legal Director at Womble Bond Dickinson 

From the time the Fourth EU Money Laundering Directive (MLD4) was adopted, there was call for change, and significant political pressure to introduce at least some changes to be implemented within the agreed MLD4 timeline. The original proposals for change (known as the fifth Money Laundering Directive (MLD5)), published in July 2016, even called for MLD4 implementation to be fast-tracked, to January 2017. This, of course, did not happen, and neither did agreement on MLD5 until nearly the end of 2017. As a result, implementation of MLD5 will now not be until mid-2019, which brings into question how the UK will implement it, given the ongoing uncertainty over how it will treat EU laws falling to be implemented after Brexit. Emma Radmore of Womble Bond Dickinson looks at what MLD5 is now almost certain to say, and its timeline for likely implementation.