Annexes to COM(2019)370 - Assessment of the risk of money laundering and terrorist financing affecting the internal market and relating to cross-border activities - Main contents
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| dossier | COM(2019)370 - Assessment of the risk of money laundering and terrorist financing affecting the internal market and relating to ... |
|---|---|
| document | COM(2019)370  |
| date | July 24, 2019 |
this report.
Directive 2006/48/EC of the European Parliament and of the Council of 14 June 2006 relating to the
taking up and pursuit of the business of credit institutions, OJ L 177, 30.6.2006, p. 1–200 and Directive
2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of
credit institutions and the prudential supervision of credit institutions and investment firms, amending
Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC, OJ L 176, 27.6.2013, p.
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provide expertise to the Commission as it explores issues relating to the use by financial services providers of electronic identification (e-ID) schemes and other innovative digital processes to comply with anti-money laundering rules.
In June 2018, the Commission published a report on restrictions on cash pay ments.40 The report concluded that restrictions on cash payments would not significantly address terrorism financing, although preliminary findings also indicated that prohibition of high value cash payments in cash could positively impact the fight against money laundering.
3.2.3. Further supporting measures
> Improving statistical data collection;
Training for professionals carrying out activities covered by ‘legal privilege’,
providing guidance and practical insights to help them recognise possible money laundering/terrorist financing operations and how to proceed in such cases. The Commission will assess options for improving compliance in this sector in line with relevant case law. An EU funded project for training of lawyers is foreseen to start by early 2020. In 2018, notaries received an EU funded grant covering anti-money laundering/countering the financing of terrorism training needs;
>* Raising public awareness about anti-money laundering/countering the financing of terrorism risks;
>* Further analysis of the risks posed by Hawala and informal value transfer services – the scale of the problem and possible law enforcement solutions;
>* Further monitoring of currency counterfeiting and its possible links to money laundering. The Commission presented a proposal for a Regulation establishing an exchange, assistance and training programme for the protection of the euro against counterfeiting for the period 2021-2027 (the ‘Pericles IV’ programme) and its extension42 to the non-euro area Member States , expected to be adopted in 2020;
>* Further work to enhance supervision in the EU. The report on the assessment of the recent alleged money laundering cases involving EU credit institutions points to possible additional actions to further strengthen the EU legislative anti-money laundering framework and hereby reinforce the Banking and Capital Markets Unions.
4. Recommendations
Having assessed the risks in light of the updated legal framework, the Commission considers that a series of mitigating measures should be taken at EU and Member State level, taking into account:
money
laundering/terrorist financing risk levels;
the need to take action at EU level or to recommend that Member States take action (subsidiarity);
financial institutions and consumer organisations. Commission Decision of 14 December 2017, C(2017) 8405 final. The group should present opinions, recommendations or reports to the Commission by December 2019.
40 COM(2018) 483 final.
41 COM(2018) 369 final
the need for regulatory or non-regulatory measures (proportionality);
and
the impact on privacy and fundamental rights.
The Commission has also taken into account the need to avoid any abuse or misinterpretation of its recommendations that would result in the exclusion of entire classes of customers and the termination of customer relationships, without taking full and proper account of the level of risk in a particular sector.
4.1. Recommendations to the European S u p e r visor y Auth or iti es
4.1.1. Follow-up to the 2017 Su pran ati o n al Risk Assessment Recomm e n dation s
In the 2017 report, the Commission recommended that the European Supervisory Authorities should:
(1) raise awareness as to money laundering/terrorist financing risks and identify the appropriate actions to further enhance the capacity of national supervisors in anti-money laundering/countering the financing of terrorism supervision;
The European Supervisory Authorities have responded in the f ollowing way by:
> issuing eight draft technical standards,43 guidelines,44 and opinions45 to support the effective implementation of the risk-based approach to anti-money
laundering/countering the financing of terrorism by credit and financial institutions and their supervisors. A ninth instrument on improving cooperation between anti-money laundering/countering the financing of terrorism supervisors is currently under consultation;
>* providing training and organising workshops on the anti-money
laundering/countering the financing of terrorism aspects of the risk-based approach, risk-based supervision; e-money risks; and money remittance risks. The workshops were attended by over 300 supervisors from all Member States; and
>* fostering the exchange of information and good practices through the European
Supervisory Authorities’ internal committees and boards of supervisors, and setting
clear expectations of supervisory practices in relation to specific issues, e.g. the Panama Papers.
These are the Joint draft Regulatory Technical Standards on a Central Contact Point to strengthen fight against financial crime (Commission Delegated Regulation (EU) 2018/1108 of 7 May 2018 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council with regulatory technical standards on the criteria for the appointment of central contact points for electronic money issuers and payment service providers and with rules on their functions, C/2018/2716, OJ L 203, 10.08.2018, p. 2–6; the Consultation Paper on the Regulatory Technical Standards on CCP to strengthen fight against financial crime (JC-2017-08); and the European Supervisory Authorities’ Joint response to the European Commission on the amendment of the draft Regulatory Technical Standards under Articles 8(5), 10(2) and 13(5) of Regulation (EU) No 1286/2014 of the European Parliament and the Council of 26 November 2014 on key information documents for package retail and insurance-based investment products, OJ L 352, 09.12.2014, p. 1–23.
The Joint Guidelines on the Characteristics of a Risk-based Approach to Anti-money Laundering and Terrorist Financing Supervision (ESAs 2016 72); the Joint Guidelines on the Joint Committee Consultation on PRIIPs with environmental or social objectives (JC 2017 05); and the Joint Guidelines on the prudential assessment of acquisitions and increases of qualifying holdings in the banking, insurance and securities sectors (JC/GL/2016/01).
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In 2018, the European Banking Authority launched a multi-annual, staff-led review of competent authorities’ approaches to the anti-money laundering/countering the financing of terrorism supervision of banks, in order to identify areas for improvement in order to establish best practices and remedy weaknesses, as well as to support national authorities' anti-money laundering/countering the financing of terrorism efforts within the
framework set by Union law and the European Supervisory Authorities guidelines. The findings will inform the content of the training that the European Banking Authority has committed to providing in 2019 and updates to the risk-based supervision guidelines under Article 48(10) of the 4th Anti-Money Laundering Directive.
(2) take further initiatives to improve cooperation between supervisors;
In November 2018, the European Supervisory Authorities consulted on draft guidelines to improve cooperation among anti-money laundering/countering the financing of terrorism supervisors. The draft guidelines clarify practical aspects of supervisory cooperation and information exchange and set out rules governing new anti-money laundering/countering the financing of terrorism colleges of supervisors. It is expected that they will be finalised in 2019.
On 10 January 2019, the European Supervisory Authorities approved the content of a multilateral agreement on the practical aspects of information exchange between the European Central Bank acting in its supervisory capacity and all competent EU authorities responsible for the supervision of credit and financial institutions’ compliance with anti-money laundering/countering the financing of terrorism obligations.
(3) develop further solutions for supervising operators acting under the ‘passporting’ regime;
The European Banking Authority has set up a task force to clarify when agents and distributors that operate in a Member State other than that in which the appointing institution is authorised are ‘establishments’ for the purposes of Directives (EU) 2015/2366,46 Directive 2009/110/EC,47 and 4th Anti-Money Laundering Directive. Work is under way and expected to be concluded in 2019.
(4) provide updated guidelines on internal governance so as to further clarify expectations around the functions of compliance officers in financial institutions;
In September 2017, the European Supervisory Authorities’ Joint Sub-committee on anti-money laundering/countering the financing of terrorism decided, in light of their own and national competent authorities’ limited resources, to postpone the drafting of guidelines on the functions of compliance officers and to focus on supervisory cooperation, which was deemed a priority as risks in this area had already materialised;
(5) provide further guidance on beneficial ownership identification for investment funds providers, especially in situations presenting a higher risk of money laundering or terrorist financing;
Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC,OJ L 337, 23.12.2015, p. 35. Directive 2009/110/EC of the European Parliament and of the Council of 16 September 2009 on the
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In June 2017, the European Supervisory Authorities published ‘risk factor guidelines’48 on simplified and enhanced customer due diligence and factors credit and financial institutions should consider when assessing the money laundering/terrorist financing risk associated with individual business relationships and occasional transactions.
The guidelines contain sectoral guidance for providers of investment funds and set out, for the first time at EU level, measures that funds and fund managers should take to comply with their customer due diligence obligations (including in respect of beneficial owners) and how to adjust the extent of the measures on a risk-sensitive basis;
(6) analyse operational anti-money laundering/countering the financing of terrorism
risks linked to the business/business model in the corporate banking, private banking and institutional investment sectors on the one hand, and in money or value transfer services and e-money on the other.
The European Banking Authority took stock of the findings from competent authorities’ thematic reviews of credit institutions and investment firms. The findings are reflected in the joint opinion on the money laundering/terrorist financing risks affecting the Union’s financial system that the European Supervisory Authorities’ are obliged to issue for each suprarnational risk assessment exercise.49
4.1.2. Current
state of play
The recommendations addressed to the European Supervisory Authorities in the 2017 supranational risk assessment have been addressed, except recommendation (4) on the provision of updated guidelines on internal governance aimed at further clarifying expectations around the functions of compliance officers in financial institutions. The Commission reiterates that recommendation (4) remains to be completed.
Furthermore, the European Banking Authority is invited to complete the relevant actions under the EU Action Plan on Anti-Money Laundering annexed to the Council Conclusions of 4 December 2018.50
4.2. Recommendations to non-financial supervisors
For the non-financial sector, there are no bodies at EU-level corresponding to the European Supervisory Authorities. Under the EU’s anti-money laundering framework, Member States may allow self-regulatory bodies to perform supervisory functions for tax advisors, auditors, external accountants, notaries and other independent legal professionals and estate agents.
The Commission reiterates the recommendations of the 2017 supranational risk assessment for self-regulatory bodies, notably to carry out more thematic inspections, raise the level of reporting; and continue to organise training schemes to develop
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Joint guidelines under Articles 17 and 18(4) of Directive (EU) 2015/849 on simplified and enhanced Customer Due Diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions; https://eba.europa.eu/docu ments/1 0180/1 890686/Fi n al+ Gu id elin es+o n +Ri s k +Facto rs +%28JC+201 7 + 3
7 %29.pdf
See section 2.2.3.
It must be highlighted that the three European Supervisory Authorities will see their role and powers
significantly reinforced in the context of the new legislative proposals on which political agreement was
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understanding of risks and anti-money laundering/countering the financing of terrorism compliance obligations.
4.3. Recommendations to Member States51
4.3.1. Follow-up to the 2017 Supranational Risk Assessment Recommendations
Under Article 6(4) of the 4th Anti-Money Laundering Directive, if Member States decide not to apply any of the recommendations, they should notify the Commission of their decision and provide a justification for it (‘comply or explain’). To date, no Member State has made such a notification to the Commission as concerns the 2017 recommendations.
The Commission followed up on the 2017 Recommendations to Member States through checks on the transposition of the 4th Anti-Money Laundering Directive, questionnaires to Member States on the follow up of 2017 recommendations and the update of the national risk assessments.
For some Recommendations the input received is either not significant or national authorities stressed the limited time available to implement them. The Commission underlines the need to maintain or intensify current efforts. Furthermore, it is important to note that the legal obligations of the 5th Anti-Money Laundering Directive supersede, either totally or in part, some of the Recommendations in the 2017 report, in particular as regards increased transparency of beneficial ownership, reduced thresholds for customer due diligence in some sectors, or extending the list of obliged entities.
(1) Scope of national risk assessments
The 2017 report identified cash intensive business and payment in cash, the non-profit organisation sector and electronic money products as areas to which Member States should give due consideration in their national risk assessments and define appropriate mitigating measures.
Most of the national risk assessments take into account the risks posed by cash-related operations and those arising from traffic in cultural artefacts and antiques, have incorporated non-profit organisations in the scope of their national risk assessments and addressed the risks of e-money products, in line with 4th and the 5th Anti-Money Laundering Directive.
However, several Member States have not yet adopted any national risk assessment,52 while others have not addressed the risk posed by the concerned products. These Member States are encouraged to urgently act on this Recommendation.
This report maintains the 2017 Recommendation and calls on all Member States to cover in their national risk assessments the risks associated with the mentioned products and to provide the appropriate mitigating measures.
(2) Beneficial ownership
The 2017 report recommended to Member States that the information on the beneficial ownership of legal entities and legal arrangements should be adequate, accurate and up to
51 For more details on the recommendations by product/service, see the accompanying Staff Working Document SWD(2019) 650.
52 At the time of the preparation of this report 13 Member States have notified to the Commission the
date. In particular, tools should be developed to ensure that the identification of beneficial ownership is done when applying customer due diligence measures and that the sectors most exposed to risks from opaque beneficial ownership schemes are effectively monitored and supervised.
The 4th Anti-Money Laundering Directive had already provided for an obligation for Member States to set up beneficial ownership registers for companies, trusts and similar legal arrangements, but the 5th Anti-Money Laundering Directive changed the context and deadline for transposition of these registers. Most Member States have notified the Commission that they have set up such registers.
This report maintains the 2017 recommendation and encourages Member States to ensure the timely implementation of the provisions set out in the 5th Anti-Money Laundering Directive related to beneficial ownership registers.53
(3) Appropriate resources for supervisors and Financial Intelligence Units
The 2017 supranational risk assessment called on Member States to allocate "adequate" resources to their competent authorities. Most Member States confirm that they have allocated adequate resources to their competent authorities, as required under Article 48(2) of the Directive. However, the report on the assessment of recent alleged money laundering cases involving EU credit institutions shows that many supervisors were critically understaffed.
This report maintains the recommendation that Member States further intensify their efforts in this area and demonstrate that anti-money laundering/countering the financing of terrorism supervisors can fully carry out their tasks.
(4) Increased on-site inspections by supervisors
Financial sector
The 2017 report recommended that Member States put in place a risk-based supervision model according to the 2016 joint guidelines on risk-based supervision of the European
Supervisory Authorities.54
Several Member States indicated that they conduct regular thematic supervisory inspections on investment firms. Others report that they carry out a general risk assessment.
The report on the assessment of recent alleged money laundering cases involving EU credit institutions shows that often supervisors did not carry out adequate on-site inspections.
Supervisors should continue to conduct on-site inspections that are commensurate, in terms of frequency and intensity, to the identified money laundering/terrorist financing risks. These must focus on specific operational money laundering/terrorist financing risks, depending on the specific vulnerabilities inherent to a product or service, in particular: institutional investment (especially through brokers); private banking, where supervisors should in particular assess compliance with beneficial ownership rules; and
53 The 5th Anti-Money Laundering Directive postpones the deadline for setting up the registers and ensuring new access rights to them. Member States have until 10 January 2020 to set up the registers for companies and 10 March 2020 to set up those for trusts.
54 See European Supervisory Authorities’ Joint Guidelines, the Risk-Based Supervision Guidelines;
07/04/2017: https://esas-joint-committee.europa.eu/Publications/Guidelines/Joint%20Guidelines%20on%20risk-
currency exchange offices and money or value transfer services, where inspections should include a review of agents’ training.
Non-financial sector
The 2017 supranational risk assessment called on Member States to ensure that their competent authorities conduct sufficient unannounced spot-checks on high-value dealers, real-estate professionals and antique traders.
Member States follow different approaches when it comes to inspections in the non-financial sectors and the quality of such supervision tends to vary more.
This report maintains the recommendation to conduct a sufficient number of on-site inspections.
(5) Supervisory authorities to carry out thematic inspections
The 2017 supranational risk assessment recommended that supervisors develop a better understanding of the anti-money laundering/countering the financing of terrorism risks to which a specific segment of the business is exposed to.
According to replies from Member States, when inspecting sectors of obliged entities, most supervisors allocate supervisory resources on the basis of risk. Supervisors’ inspections usually cover compliance with beneficial owner and training requirements among others. In most replies, there is no mention of thematic inspections in the money or value transfer services sector in the last two years. Supervisors should continue to improve their understanding of the money laundering/terrorist financing risks to which a specific segment of the business is exposed. They should specifically assess compliance with beneficial ownership rules in the sectors identified in 2017.
This report maintains the recommendation that Member States further ensure that supervisors carry out thematic inspections. In addition, supervisors should better focus their resources in thematic inspections.
(6) Considerations for extending the list of obliged entities
The 2017 report pointed at some services/products which were not covered by the EU anti-money laundering/countering the financing of terrorism framework and called on Member States to extend the scope of the anti-money laundering/countering the financing of terrorism regime to professionals particularly at risk.
The 4th Anti-Money Laundering Directive extended the scope of the anti-money laundering/countering the financing of terrorism regime to those professionals. Most Member States’ replies and the transposition check show that generally this recommendation was followed. Moreover, some Member States already apply the 5th Anti-Money Laundering Directive provisions as regards new obliged entities.
This report maintains the recommendation to pay close attention to professionals particularly at risk, including new obliged entities introduced by the 5th Anti-Money Laundering Directive (estate agents, art and antiques dealers and specific traders in high-value goods if they accept cash payments above a certain threshold; virtual currencies exchange platforms and wallet providers).
(7) An appropriate level of customer due diligence for occasional transactions
The 2017 report drew attention to the exemption from customer due diligence of occasional transactions below EUR 15 000 and called on Member States to define a
The threshold for occasional transactions varies across Member States. Some apply thresholds for money or value transfer services or currency exchange offices that could still be considered high. As a result, efficient monitoring of transactions is more difficult.
This report maintains the 2017 recommendation and calls on Member States to provide guidance on the definition of ‘occasional transactions’ and to set out criteria that ensure that the customer due diligence rules applicable to business relationships are not circumvented for currency exchange offices and money remittances;
(8) Appropriate level of customer due diligence for safe custody and similar services
The 2017 report recommended that appropriate safeguards are put in place to monitor safe custody services properly, in particular those provided by financial institutions and similar storage services provided by non-financial providers.
Replies from Member States show that these activities are subject to anti-money laundering/countering the financing of terrorism regulation regardless of whether developed by a credit institution or not. In some Member States only financial institutions are providing these services.
This report maintains the recommendation to ensure an appropriate level of customer due diligence for safe custody and similar services.
(9) Regular cooperation between competent authorities and obliged entities
The 2017 report recommended enhanced cooperation in order to make detecting suspicious transactions simpler, to increase the number and the quality of the Suspicious Transactions Reports, to provide guidance on risks, customer due diligence, and reporting requirements. This can be mainly achieved through feedback from Financial Intelligence Units to the obliged entities on the quality of reporting but also on typologies. Several sectors have stressed the lack of feedback as a problem in particular: gambling, tax advisors, auditors, external accountants, notaries and other independent legal professionals and money or value transfer services.
The analysis and the assessment for the purposes of the report assessing the framework for cooperation between Financial Intelligence Units showed that in many Member States feedback from Financial Intelligence Units to obliged entities is still deficient, despite the existence of internal regulations and sectoral guidelines as regards this requirement.
This report partly maintains the recommendation and calls for enhanced cooperation between competent authorities and obliged entities.
(10) Special and ongoing training for obliged entities
The 2017 report recommended that training by competent authorities should address the risk of infiltration or ownership by organised crime groups, in particular for the gambling sector, trust and company services providers, tax advisors, auditors, external accountants, notaries and other independent legal professionals, some service providers (on capital structure, industrial strategy, mergers and the purchase of undertakings), real estate and money or value transfer services.
Most Member States reported that training has been provided as recommended, as well as guidance on anti-money laundering/countering the financing of terrorism obligations for different sectors.
This report maintains the recommendation to provide further training, especially with regard to obliged entities particularly at risk, as identified in the 2017 supranational risk assessment, or for newly designated obliged entities.
(11) Annual reporting from competent authorities/self-regulatory bodies on the anti-money laundering/countering the financing of terrorism activities of the obliged entities under their responsibilities
The 2017 supranational risk assessment showed that this reporting obligation helped national authorities to conduct National Risk Assessments and allowed for more proactive action to deal with weaknesses or failures to comply with anti-money laundering/countering the financing of terrorism requirements in particular in the real estate sector and for tax advisors, auditors, external accountants, notaries and other independent legal professionals.
In some Member States, self-regulatory bodies have only recently begun their supervisory activity because certain sectors, mainly designated non-financial business and professions, have only been added through the 4th Anti-Money Laundering Directive. Therefore there are as yet detailed statistics as requested in the recommendation to designated non-financial business and professions. Some Member States disagree on the utility of annual reporting on supervisory activities.
This report maintains the recommendation and encourages self-regulatory bodies to perform a more proactive role in anti-money laundering supervision.
4.3.2. Risk analysis by product/service
specific recommendations
In addition to the above recommendations, there is a need for the following product/sector-specific action:55
(1) Cash and cash-like assets
>* In their national risk assessments, Member States should take into account risks posed by cash payments and take appropriate mitigating measures.
>* Authorities should act on amounts below the EUR 10,000 declaration threshold where they suspect criminal activity.
(2) Financial sector
>* Member States should improve the monitoring and detection systems applying to products which are more exposed to terrorist financing risks. Financial institutions usually do not have access to relevant information (often held by law enforcement authorities) that would help them identify terrorist financing risks
before they materialise. Likewise, law enforcement authorities’ efforts to disrupt
terrorist activities and networks can be hampered by their inability to obtain
information on financial flows that only financial institutions can provide; >* As regards money laundering risks, it is essential that Member States develop and
improve their beneficial ownership registers to assist in carrying out robust
customer due diligence processes; >* Member States should continue to conduct thematic inspections, focusing on
different areas depending on the sector/product For on-site inspections in
relevant companies in a particular sector, it is more time-efficient to select risk
areas than to conduct an overall inspection; this gives supervisors a clear picture
of best practices and the most significant shortco mings; >* Provision of training and guidance on risk factors such as non-face-to-face
interaction, offshore professional intermediaries/customers and c ompl e x/shell
structures: and >* Follow up on the findings of the report on the assessment of recent alleged money
laundering cases involving EU credit institutions.
(3) Non-fi nancial sector and products ---- Designated non-financial businesses and
professions
> Member States should ensure that competent a uthorities/self-re g ulatory bodies provide training and guidance on risk factors, with a specific focus on non-face-to-face business relationships, offshore professional intermediaries/customers or jurisdictions, and complex/shell structures;
> Member States should ensure that se lf- re g ulato ry bodies/competent authorities conduct thematic inspections on compliance with beneficial owner identification requirements;
> Competent a uthorities/self-re g ulatory bodies should provide Member States with
annual reports on measures carried out to verify the obliged entities’ compliance
with their customer due diligence obligations, including beneficial owner requirements, Suspicious Transaction Reports and internal controls; and >* Member States should ensure that service providers offering advice to undertakings on capital structure, industrial strategy and related questions, and advice and services relating to mergers and the purchase of undertakings comply with their beneficial owner obligations.
(4) Gambling sector
K Competent authorities should put in place programmes to raise awareness among (online) gambling operators of the emerging risk factors that may affect the vulnerability of the sector, including the use of anonymous e-money and virtual currencies and the emergence of unauthorised online gambling operators. Feedback from Financial Intelligence Units on the quality of the Suspicious Transaction Reports would improve the reporting and the use made of the information provided. Financial Intelligence Units should take account of the specificities of the gambling sector when developing standard Suspicious Transaction Report te mpl ates at EU level.
>* In addition to training sessions, Member States should ensure adequate training focusing on appropriate risk assessments of relevant products/business models for staff, compliance officers and retailers; and
> Further guidance should be given to obliged entities on the concept of ‘several operations which appear to be linked’.
(5) Collection and transfers of funds through a non-profit organisation
r Member States should ensure that non-profit organisations are more involved in
national risk assessments; >* Member States should develop information and a ware ness-ra isi ng programmes
on the risk of non-profit organisations being abused and provide
awareness-raising materials for them; and >* Member States should further analyse the risks faced by non-profit organisations.
(6) New products/sectors ---- professional football, free ports, investor citizenship and
residence schemes
>* Professional football – Member States should consider which actors should be covered by the obligation to report suspicious transactions and what requirements should apply to the control and registration of the origin of the account holders and the beneficiaries of money.
>* Free ports – Member States should implement independent, regular anti-money
laundering audits of agreed free zone operators’ compliance functions and ensure
>* Investor citizenship and residence schemes — Member States should consider the money laundering risks of investor citizenship and residence.
5. CONCLUSION
The Commission will continue to monitor the implementation of the recommendations of this supranational risk assessment and report again by 2021. The review will also assess how EU and national measures affect risk levels, and will examine the impact of more recent changes to the regulatory framework. The Commission will also conduct a study on the effective implementation of the 4th Anti-Money Laundering Directive by Member States.