Ambiguities in measures to combat money-laundering in the European Union

Abstract

Money laundering poses a great threat to the financial system of the EU, therefore, effective measures must be in place to protect the financial system. This research establishes that the measures provided by the EU in the 4AMLD contain ambiguities disturbing the protection of the financial system. Such ambiguities are the unclear risk assessment that has to be conducted before carrying out customer due diligence; challenges to the principle of legal certainty and vague phrases contained in the provisions dealing with the transparency of beneficial owners; and unclear exemptions from lawyers’ obligation to report, thus challenging the legal professional privilege.