Looks Easy, but It Is Complicated: Updates to the EU Money Laundering Directive
Although the 4th EU Money Laundering Directive and its national implementation basically “only” substantiates existing standards, they cause the financial industry to face new challenges. In addition to the new guidelines, the continuously increasing frequency of publications (the 5th EU Money Laundering Directive is already being prepared) and the scope of the subject areas, which are attributable to the generic term “compliance”, cause increasing complexity. This is intensified by the fact that it results in an area of tension between individual compliance requirements. Consequently, the requirements for combating money laundering (new Money Laundering Act) and data protection (DSGVO) are not compatible with one another. This can result in contradictions in daily work. Furthermore, economic interests, for example instant payments, often make the implementation of compliance requirements difficult. The 4th EU Money Laundering Directive and its national implementation move within this area of tension.