On 2 July 2020, the European Commission announced that it had referred Austria, Belgium and the Netherlands to the Court of Justice of the European Union, with a request for financial sanctions, for failing to fully implement the Fourth Anti-Money Laundering Directive into their national law.

The Commission states that incomplete transposition concerns fundamental aspects of the anti-money laundering framework, such as betting and gambling legislation (Austria), mechanisms under which the Financial Intelligence Units exchange documents and information (Belgium), and the information to be provided on the beneficial ownership of corporate and other legal entities (Netherlands).