Controversially, authorities have confirmed that the EC has referred Luxembourg to the European Court of Justice (ECJ) for failing to entirely implement the EU Directive 4th Anti-Money Laundering Directive (4AMLD), over 17 months after the published timeframe which ended on June 26th 2017. The European Commission recommends that the ECJ charges a one-off fine for non-compliance and daily penalties going forward until Luxembourg takes appropriate action.
It has emerged that 2 additional Member States (Romania and Ireland) face imminent court referrals whilst Greece has a blanket exception for non-adoption for now. Eight other jurisdictions are at the stage of Reasoned Opinions; whilst 7 further have received letters of formal notice for postponement of the 4th AMLD. All of these legal proceedings have taken place while the EU is already in the process of implementing a 5th Directive.