EU Anti-Money Laundering and Countering the Financing of Terrorism (EU AML/CFT) Package published
The EU Anti-Money Laundering and Countering the Financing of Terrorism (EU AML/CFT) Package was finally published in the Official Journal of the European Union on 19 June, following adoption by both the European Parliament and the Council.
The Package comprises of a AML/CFT Regulation (AMLR) which will be officially applied on 10 July 2027, a 6th Anti-Money Laundering Directive, which must be transposed into national legislation by 10 July 2027 and the Regulation which establishes the Anti-Money Laundering Authority that will officially apply from 1 July 2025.
While the Package, specifically the AMLR, provides some clarity on the issue of the identification of Beneficial Owners (BOs) for non-profit organisations, there are several items of unclarity and concern. We refer, for example, to the consideration of public benefit crowdfunding platforms and cryptoassets service providers as obliged entities, as well as the identification as BOs of individuals who often to not have ownership or control in the case of foundations similar to express trusts.
Philea, together with the European Center for Not-for-profit law (ECNL) and some additional legal experts, will produce an in-depth briefing note on the Package, which will be published in the coming months.
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