On the day that the Fourth Anti-Money Laundering Directive (4MLD) entered into force (26 June 2017) the European Commission also published for the first time a report on the supra-national risk assessment (SNRA) of the risks of money laundering (ML) and terrorist financing (TF) affecting the internal market and relating to cross-border activities.
In the report the Commission identifies 40 products or services that are considered potentially vulnerable to ML/TF risks affecting the internal market. These cover 11 professional sectors, including all those defined by the 4MLD, along with some not included in the scope of the Directive but considered relevant for the SNRA.
The SNRA uses a defined methodology to provide a systematic analysis of the ML or TF risks linked to the modi operandi used by perpetrators. The aim is not to pass judgment on a sector as a whole, but to identify circumstances in which the services and products it delivers or provides could be abused for TF or ML purposes. The SNRA is based on the legislation in force at the time of the analysis, i.e. the Third Anti-Money Laundering Directive.
The report also presents certain mitigating measures that should be pursued at EU and national level to address these risks and puts forward a number of recommendations for the different actors involved in the fight against ML and TF.
While the Commission acknowledges the risks posed by some high-risk third countries, such geographical risk analysis was not part of this SNRA. The Commission states that this is due to the fact that the analysis of the risks posed by these jurisdictions is currently conducted in the context of a separate process, namely the Commission delegated acts identifying third country jurisdictions which have strategic deficiencies that pose significant threats to the EU financial systems for ML / TF.