HMT has opened a consultation on the implementation of MLD5. Treasury proposes a number of changes to UK law, and seeks views on its proposals in several areas. Aspects of MLD5 addressed in the consultation include:
- what the expanded definition of “tax adviser” and the term “letting agent” should encompass;
- how to define virtual currencies and whether the MLD5 definition is appropriate to capture exchange, security and utility tokens, and whether FCA should be the AML supervisor;
- exemptions available in relation e-money products;
- clarity on the use of electronic identification processes;
- how to define a business relationship or transaction involving a high risk third country; and
- a national register of bank account ownership.
Responses to the consultation are welcomed until 10 June 2019. MLD5 requires implementing measures to be in force by 10 January 2020.