Global

A Third EU Money Laundering Directive – when less is more

Edina Cavalli and Duncan Aldred, of the Banking and International Finance Group and Charles Spragge, of the Commercial Litigation Group of CMS Cameron McKenna

On 22 March 2004, the European Commission published its draft proposal for a Third Money Laundering Directive and a formal Commission proposal for the Directive was presented on 30 June 2004 (the ‘formal proposal’). The Directive’s aim is to update and, for the sake of clarity, replace the 91/308/ECC (First Money Laundering Directive) as amended by Directive 2001/97/EC (Second Money Laundering Directive) and to incorporate the Financial Action Task Force’s (FATF) revised 40 Recommendations, as well as the FATF Special Recommendations on Terrorist Financing. The Directive will now cover not only money laundering but also terrorist financing.