The UK has already made much progress. The National Risk Assessment Money Laundering and Terrorist Financing Risk Assessment was published in October 2015, followed by a National AML Action Plan this year.

The Persons of Significant Control Register (effectively a beneficial ownership register) became publicly accessible in June.
In September 2016, the UK Government launched its transposition consultation exercise.

To view the consultation click here

Although the European Commission has already proposed amendments to 4MLD, HM Treasury’s consultation addresses it as originally adopted. The current Money Laundering Regulations and Transfer of Funds Regulations will be revoked and replaced with a new single regulation – The Money Laundering and Transfer of Funds (Information on the Payer) Regulations 2017 effective by the 26 June 2017.

This means that the new Regulation will be in effect by the time that the FATF Mutual Evaluation of the UK’s AML/CTF regime commences in late 2017.

The wide ranging consultation is a mixture of policy indications and calls for evidence and addresses matters such as risk-based customer diligence, PEPs, availability of trust beneficial ownership data, possible exemptions for the gambling sector, estate and letting agents, and e-money.
Given the length of the consultation exercise and time required for the Government to consider the responses, we estimate that draft Regulations will be available in early 2017.

To have a look at some of the key changes to the 4MLD click here