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CMS Expert Guide to the transparency register in AML directive

Transparency Register pursuant to the fourth European Money Laundering Directive – Status of Implementation in Selected EU Member States


In 2015, the Fourth Money Laundering Directive (Directive EU 2015/849) required EU member states to set up registers of the ultimate beneficial owners of legal entities. That Directive has recently been amended by the Fifth Money Laundering Directive (Directive EU 2018/843), and as a consequence most EU member states have made significant changes to their existing domestic law regimes, including amendments required by the new Directive.

To provide an initial overview, CMS has summarised the current regulations in selected EU member states. Of particular relevance to shareholders are the countries where direct and indirect shareholders have an obligation to act.