The Novel Eu Anti-Money Laundering Legal Framework: The Race Has Started Again…
November 25, 2018
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by Dalila DELORENZI (FREE Group Trainee)*
After 2 years, the procedure of revision of the novel European Union Anti-Money Laundering (AML) framework finally came to an terminate on xx May, when the European Parliament at its minute reading adopted the Fourth AML Directive (Directive (EU) 2015/849) along amongst the new Regulation on information on the payer accompanying transfers of funds (Regulation (EU) 2015/847).
The revision was triggered yesteryear the necessity to adjust the legal framework to counter novel threats of coin laundering as well as terrorist financing as well as to reverberate recent changes due to revised Financial Actiont Task Force (FATF) Recommendations. The next weblog postal service presents the new legal framework, including some crucial measures which could stand upward for a existent step-up inwards the struggle against coin laundering, financing terrorism as well as taxation evasion.
1. Introduction of an European register of beneficial ownership
The creation of an European register of beneficial ownership was 1 of the sticking points of the negotiations, as well as was the argue why the text attracted much to a greater extent than political attending than the previous directives as well as why the negotiations took much longer than was expected.
1.1 definition of beneficial ownership as well as the problems caused yesteryear “phantom firms”
A beneficial owner is a natural person – a real, alive human beingness as well as non some other fellowship or trust – who stands behind a fellowship (or trust) equally the ultimate possessor as well as controller, direct or indirectly exercising substantial command over the fellowship or receiving substantial economical benefits (such equally receipt of income) from the company. If the truthful owner’s holler is disguised, nosotros bargain amongst “anonymous companies”. In a bulk of countries, keeping unknown the truthful owner’s holler is perfectly legal as well as at that spot is typically no requirement to divulge that the names listed are just front-people.
Such anonymous companies tin live created yesteryear using “nominees”, people who front end the fellowship inwards house of the truthful owner, or yesteryear incorporating 1 or to a greater extent than of the companies inwards a province which does non brand details of the beneficial owners publicly available. Also called “phantom firms”, they be solely on paper, amongst no existent employees or office. While it’s sure enough truthful that such entities tin take away hold legitimate uses, the untraceable fellowship tin also live a vehicle of pick for crimes such equally coin laundering, taxation evasion as well as financing of terrorism.
1.2 The role of anonymous companies inwards coin laundering
Although at that spot are countless ways to wash money, coin laundering tin live broken downward into 3 stages:
§ Placement: the initial entry of illicit coin into the fiscal system. This mightiness live done yesteryear breaking upward large amounts of cash into less conspicuous smaller sums that are as well as so deposited direct into a banking concern account.
§ Layering: the minute footstep consists inwards the procedure of separating the funds from their source. This purpose is oftentimes followed yesteryear using anonymous vanquish companies: for instance, wiring coin to concern human relationship owned yesteryear anonymous vanquish company.
§ Integration: coin re-enters the legitimate economy, for instance, yesteryear investing the funds into existent estate as well as luxury assets.
That beingness said, it is clear that these secretive “shell” companies as well as trusts play a primal role inwards laundering as well as channelling funds, concealing behind a veil of secrecy the identity of corrupt individuals as well as irresponsible businesses involved inwards activities, including taxation evasion, terrorist financing, as well as the trafficking of drugs as well as people. More precisely, it is impossible for law enforcement officials instruct dorsum to the existent individuals ultimately responsible for the company’s actions as well as to runway the beginning of illicit funds.
§ 1.3 The importance of primal registers
Broadly speaking, amongst a persuasion to facing the chance of coin laundering (along amongst financing terrorism as well as taxation evasion), the solution may live to know who ultimately stands behind a company: the existent possessor or controller.
For this argue – as well as also next the FATF’s version of the Directive that would take away hold required every European Union Member State to institute ownership registers as well as brand the information freely available to the public. “The world registers volition brand life to a greater extent than hard for criminals trying to enshroud their money. Our economic scheme currently loses huge amounts to taxation evasion”, said Civil Liberties Committee rapporteur Judith Sargentini (Greens/EFA, NL).
Instead, the Council released its ain draft in June 2014, that would also take away hold mandated primal registers, but without requiring world access. The Council’s approach was to throttle the access to competent authorities, Financial Intelligence Units (hereinafter FIUs) and, if allowed yesteryear Member States, the obliged entity, e.g., banks as well as legal professions.
1.5. …a compromise was reached
The lastly text struck a compromise between these initial positions: on the 1 manus those who demand total transparency (such equally the European Parliament, which voted 643-30 inwards favour of world registries as well as some Member States equally UK, France, Netherlands as well as Denmark); on the other manus those who defend some secrecy for beneficial owners (some Member States led yesteryear Germany).
The compromise reached requires European Union countries to render access non solely to law enforcement as well as fiscal institutions similar the FIUs, but also to members of Blue Planet who tin demonstrate a “legitimate interest” inwards the information. They volition live able to access beneficial ownership information – such equally the beneficial owner’s name, calendar month as well as yr of birth, nationality, residency as well as details on ownership – as well as the access may live dependent area to online registration of the somebody as well as to the payment of a fee to encompass administrative costs. Any exemption to the access would live possible solely on a case-by-case ground inwards exceptional circumstances.
In conclusion, the collection of ownership information is sure enough a large footstep inwards the right direction, but non equally large equally it should take away hold been. In fact, fifty-fifty if the Directive does non forbid countries from going beyond the Directive’s requirements as well as opening their registries to total world access – equally Great Britain as well as Kingdom of Denmark take away hold already said they volition do – “European leaders take away hold missed an chance to demo that the hereafter of concern inwards Europe is opened upward as well as transparent”, said Robert Palmer, an anti-money laundering movement leader at Global Witness, Furthermore, a Commission study on the interconnection of national registers is expected yesteryear June 2019.
1.6. Influenza A virus subtype H5N1 “legitimate interest” is required to access…
As termination of the lastly compromise, the members of Blue Planet take away hold the right to access registers solely if they take away hold a legitimate interest, narrowing inwards this way the number of people having the right to access registers. So, to those who take away hold pointed out that this does non arrive plenty inwards damage of the EU’s ambitions on transparency, the co-rapporteur Judith Sargentini assured that they made sure that the proposal says that it’s upward to the authorization to essay that applicants do not take away hold a legitimate interest.
Nevertheless, at that spot is an of import number left open: there is no indication of what interests volition live considered legitimate. Indeed, the concept of “legitimate interest” itself is quite vague as well as the lack of a clear definition entails that it lies amongst Member States to create upward one's hear what a legitimate involvement should be.
1.7. Influenza A virus subtype H5N1 dissimilar regulation for trusts…
A dissimilar regulation is provided for trusts, regarding inwards particular 3 aspects:
§ the regulation expects that information volition live collected in closed centralised registries available solely to authorities bodies. This information includes the identity of the settlor, the trustee(s), the protector (if any), the beneficiaries or shape of beneficiaries, as well as of whatsoever other natural somebody exercising effective command over the trust. Clearly the fact that such information will not be available to the public can create a loophole inwards the scheme which could significantly weaken the novel directive, frustrating as well as so the aim of improving transparency. This loophole was due to the UK, where trusts are quite common, as well as it was justified yesteryear the co-rapporteur Timothy Kirkhope saying: “I heard some concerns as well as if I may just say on the number of trusts as well as wills: trusts as well as wills contain some of the most private as well as personal information that at that spot is almost a person, as well as nosotros are a parliament that respects information privacy, so disclosure for trusts has to live proportionate inside our proposals.”.
§ the registration of beneficial owners of trusts only when a trust “generates taxation consequences”: such wording is arguably also wide as well as highly susceptible to evasion risk
§ the central registration of beneficial ownership information volition live used where the trust generates consequences equally regards taxation (Article 30). Regarding legal persons, instead, Article 29 of the Directive foresees that the location of the beneficial possessor register shall live the province yesteryear whose laws the legal somebody is governed. This is a key number because if it is non made clear that trust registers demand to live located inwards the countries yesteryear whose laws the trust is governed, at that spot is a high chance for that whatsoever other location would non serve the purpose of enforcing transparency, specially considering the fact that trusts are non recognized inwards the bulk of Member States! (See also the declaration by Republic of Austria expressing concern almost trusts).
1.8. European Union equally a model to follow?
In closing on beneficial ownership information, nosotros may say that fifty-fifty if the European Union institutions could take away hold gone fifty-fifty farther inwards damage of transparency, the understanding reached sharply contrasts amongst the lack of progress inwards the United States. The U.S. is, indeed, notorious internationally for allowing anonymous companies to live formed.
“So allow us brand this an illustration for other countries inwards the world. Would it non live fantastic if the USA were to follow us, would it non live marvellous inwards our struggle against taxation avoidance as well as taxation evasion? I desire everyone to assist us gain that.”, said the co-rapporteur Judith Sargentini at the terminate of her intervention at the MEPs fence inwards plenary session.
2. The Risk-Based Approach
The risk-based approach is some other hot topic as well as a novel chemical element of the 4th AML directive. The thought is that the chance of coin laundering is non exactly the same inwards every situation. It’s as well as so of import to live able to sympathise what the risks of coin laundering as well as financing terrorism are inwards guild to adjust client due diligence (CDD) measures to dissimilar situations: focusing resources on those areas where is demonstrated that risks are higher as well as giving the possibility to apply simplified due diligence when risks are lower.
In other words, introducing a risk-based approach agency that countries, competent authorities as well as reporting entities are expected to identify, assess as well as sympathise the coin laundering equally good equally terrorist financing risks they are exposed to, so that they tin prepare the appropriate measures to mitigate as well as improve target these risks. This activity volition live supported at 4 dissimilar levels:
1. European Union: supranational chance assessment, carried out yesteryear the Commission, aimed to pinpoint risks related to the internal market.
2. Member States: national chance assessment to sympathise exactly where the chance appears or may be inside their specific jurisdictions.
3. Institutions as well as persons covered yesteryear the Directive
4. Supervisors: supervisory authorities such equally ESMA as well as EBA (the EU’s fiscal services regulatory agencies).
Certainly, this is a principal modify compared to the tertiary AML Directive where nosotros had 3 scenarios: simplified, normal as well as enhanced CDD rules. In the 4th Directive, instead, CDD-rules are to a greater extent than chance sensitive: it all depends on what variety of risks exist, discerning betwixt enhanced measures where risks are greater as well as simplified measures where risks are demonstrated to live less. Nevertheless, at that spot are some particular cases where obliged entities shall live required to apply Enhanced Customer Due Diligence. More precisely, this applies: when dealing amongst clients inwards tertiary province identified equally “high risk”; inwards cases of cross-border correspondent relationships amongst tertiary countries; inwards transactions involving Politically Exposed Persons (and household unit of measurement members); as well as inwards complex as well as unusually large transactions which take away hold no economical or lawful purpose. In whatsoever other case, the risk-based approach is applied, removing the automatic entitlement to apply Simplified Customer Due Diligence when dealing amongst specified customers as well as products.
3. Politically Exposed Persons (PEPs)
3.1. What is a Politically Exposed Person as well as what are the risks associated?
The Third AML Directive defines “politically exposed persons” as natural persons who are or take away hold been entrusted amongst prominent world functions such equally Heads of State or of government, senior politicians, senior government, judicial or military machine officials, senior executives of province owned corporations, of import political political party officials. Immediate household unit of measurement members or persons known to live unopen associates of such persons are included inwards the definition.
Due to the seat they hold, it is recognised that many PEPs are inwards positions that potentially tin live abused for the purpose of committing coin laundering offences as well as related predicate offences, including corruption as well as bribery, equally good equally conducting activity related to terrorist financing. So, inwards instance of concern relationships amongst PEPs, it was felt necessary to position inwards house preventive measures, specially anti-money laundering as well as counter-terrorist financing measures.
3.2. The tertiary AMLD as well as the FATF standards
To address such potential risks associated amongst PEPs, inwards 2003 the Financial Actions Task Force released obligatory requirements for unusual PEPs (whether equally client or beneficial owner). In particular, inwards add-on to normal client due diligence measures, financial institutions should live required to:
§ have appropriate risk-management systems to determine whether the client or the beneficial possessor is a politically exposed person;
§ obtain senior administration blessing for establishing (or continuing, for existing customers) such concern relationships;
§ take reasonable measures to institute the source of wealth as well as source of funds;
§ conduct enhanced ongoing monitoring of the concern relationship.
Following the international standards, the tertiary AML Directive envisaged that obliged entities are required to apply enhanced client due diligence measures amongst observe to PEPs, solely regarding to PEPs who reside inwards some other Member State or inwards a tertiary country (i.e. foreign PEP).
3.3. Fourth AMLD enlarges PEPs regime…
Taking concern human relationship of the FATF recommendation adopted inwards 2012 as well as next the aim of enhancing due diligence, the 4th AMLD extends the requirements provided for foreign politically exposed persons to domestic PEPs and PEPs of international organizations. The departure betwixt dissimilar type of PEP depends on who has entrusted the private amongst the prominent world function, i.e. the province inwards query or some other province or an international organisation.
In particular, in cases of a higher chance concern relationship with a client or beneficial possessor who is a domestic PEP or a somebody who is or has been entrusted amongst a prominent business office yesteryear an international organisation, financial institutions should live required to apply the same measures equally those that are applied to unusual PEPs. It should live also noted that a domestic PEP is dependent area to the unusual PEPs requirements if that private is also a unusual PEP through some other prominent world business office inwards some other country. In brief, the fourth AML Directive does non brand such a distinction, as well as automatic enhanced due diligence measures volition live required inwards the instance of whatsoever PEP, regardless of where they originate from.
4. Coverage of the gambling sector
Casinos as well as gambling services are oftentimes a target for coin launderers, attracted yesteryear their nature of “cash intensive business”, where the bulk of transactions are cash based. Therefore, some other essential topic discussed concerns whether the ambit of the Directive volition encompass all gambling operators (even those viewed equally depression risk) or solely casinos as well as online gambling operators.
With a persuasion to facing novel emerging threats, it was felt the demand to extend the ambit of the tertiary AMLD, inwards which solely casinos were required to apply Customer Due Diligence (CDD). The novel directive indeed brings into the scope all providers of gambling services when dealing amongst transactions of at to the lowest degree €2,000.
Nevertheless, inwards the lastly compromise a proportionate risk-based approach was introduced. If, later on conducting a chance assessment, European Union Member States discover that at that spot is a “proven depression risk” of coin laundering as well as terrorist financing, because of “the nature and, where appropriate, the scale of operations of such services”, they are able to exempt sure gambling operators – although non casinos – from some or all requirements, inwards strictly limited as well as justified conditions.
5. A novel Regulation on the traceability of fund transfers
In parallel amongst the revision of the coin laundering Directive, a Regulation on the transfer of funds was also approved. The 2 legislative measures pursue the mutual objective of revising the existing anti-money laundering as well as counter terrorist financing European Union framework inwards guild to improve its effectiveness spell ensuring its compliance amongst international standards. In particular, the novel Regulation is based on Recommendation sixteen on wire transfers adopted yesteryear the Financial Action Task Force.
Besides, the pick of a Regulation aims to ensure that this international measure is transposed uniformly throughout the Union and, inwards particular, that at that spot is no discrimination betwixt situations involving national payments inside a Member State as well as cross-border payments betwixt Member States.
5.2 What is it about?
The Regulation is about tracking transfers of funds, inwards whatsoever currency, sent or received yesteryear a Payment Service Provider (PSP) established inwards the Union. The tracking is implemented yesteryear placing certain requirements on the information that accompanies transfers and applies to all the PSPs involved inwards the payment chain. The basic logic behind is: the higher the amount as well as the higher the chance of irregularity, the to a greater extent than checks as well as controls nosotros should take away hold inwards place. Indeed, collecting basic information on the transfers may assist appropriate law enforcement and/or prosecutorial authorities inwards detecting, investigating, prosecuting terrorists or other criminals as well as tracing the assets of terrorists. For this reason, it is essential ensuring that transfers of funds contain complete, accurate as well as meaningful information on the payer.
5.3. What changed from the previous legislation?
The Regulation which was repealed (i.e. Regulation EC 1781/2006) already required Payment Service Providers to accompany transfers of funds amongst information on the payer. New rules also require information on the payee (the somebody who receives the payment) to live included. More precisely, the payer’s PSP must: a) ensure transfers of funds are accompanied yesteryear information almost the payer (as name, payment concern human relationship number etc.); b) verify the information on the payer, using “documents, information or information obtained from a reliable as well as independent source”; c) ensure that transfers of funds are also accompanied yesteryear the holler of the payee as well as the payee’s concern human relationship number.
For its part, the payee’s PSP must live able to discover a lack of presence of information on the payer when receiving transfers as well as take away hold appropriate steps inwards guild to right this situation: inwards this way, transfers of funds received yesteryear the payee do non stay anonymous. In addition, the Regulation requires verification of information on the payee (such equally his holler as well as his payment concern human relationship number) when transfers of funds overstep €1000, earlier the PSP credits the payee’s concern human relationship or makes the funds available to the payee. Verification of this information is non required inwards other cases, unless the payee’s PSP has reasonable grounds for suspecting coin laundering or terrorist financing.
5.4. Not solely recording information but also…
While verifying as well as recording information, the PSP must exert a special vigilance regarding such transfers and, on a chance sensitive ground as well as taking into concern human relationship other pertinent factors, report suspicious transactions to the authorities responsible for combating coin laundering as well as terrorist financing. PSPs should also response fully as well as chop-chop to enquiries yesteryear such authorities.
6. Cooperation betwixt Financial Intelligence Units (FIUs)
6.1. What are FIUs?
In the early on phases of the evolution of the AML regime it became obvious that skilled personnel were needed to sympathise trends inwards coin laundering as well as to brand sense of the huge amounts of information beingness produced yesteryear financial institutions nether reporting obligations. In response to this need, as well as to the demand for a centre of analysis as well as dissemination of fiscal intelligence, FATF Recommendation 26 called for the establishment of entities commonly referred to equally “financial intelligence units” or “FIUs”.
Adjusting the European Union legal framework to the international standards, the Third AMLD required each Member State to establish specialized governmental agencies to bargain amongst the job of coin laundering as well as other fiscal crimes. Influenza A virus subtype H5N1 FIU, quite simply, is a central, national body responsible for receiving (and equally permitted, requesting) financial information, concerning suspected proceeds of criminal offence as well as potential financing of terrorism, or other information required yesteryear national legislation or regulation. Influenza A virus subtype H5N1 FIU is as well as so responsible for processing that information inwards some way as well as disclosing it to an appropriate authorities authorization inwards back upward of a national anti-money laundering effort.
6.2. Strengthening of their role amongst the 4th AMLD
The Fourth AMLD aims to strengthen the role of FIUs as well as their cooperation in observe of exchanging information. In particular, the Regulation requires the FIU to be operationally independent as well as autonomous. In other words, the FIU must take away hold the authorization as well as capacity to ship out its functions freely, including the autonomous conclusion to analyse, asking as well as disseminate specific information. Also the FIU must live provided with adequate financial, human as well as technical resources in guild to fulfil its tasks.
Moreover, Member States must ensure that the FIU is empowered to take urgent action, either direct or indirectly, when at that spot is a suspicion that a transaction is related to coin laundering or terrorist financing, to suspend or withhold consent to a transaction going ahead inwards guild to analyse the transaction, confirm the suspicion as well as disseminate the results of the analysis to competent authorities.
Nevertheless, it is non made clear, equally it wasn’t either inwards the tertiary AMLD, the mode inwards which the FIUs tin accomplish their goals. The text does non clarify their nature which brings to the fact that the organisational nature of FIUs differs across Member States: they tin live administrative, judicial, or police pull structures. The job as well as so is that having dissimilar powers tin create difficulties inwards exchanging information, including the possibility to access information, amongst consequences for the effectiveness of cooperation.
7. Strengthening Data Protection
The lastly but non to the lowest degree number discussed during negotiations concerns information protection rules – specially the demand to elevate effectiveness of AML prevention spell ensuring a high degree of protection of personal data. Both world as well as private stakeholders take away hold pointed to a number of difficulties regarding the compliance of the AML requirements amongst a high degree of protection of personal data. Indeed, nether the AML legislation, the requirements to collect as well as procedure information (e.g. to monitor transactions as well as client relations against sanctions lists, to seat beneficial owners, to maintain records for criminal investigation purposes, etc.) increase the amount of information beingness collected, along amongst the possible consequences for information subject.
In the previous AML legislation, at that spot was a lack of clarity almost how these requirements were to live reconciled amongst rules on information protection, inwards particular at national level, which was leading to incoherent approaches across Member States. So during negotiations for the Fourth AMLD, the European Parliament voted for a important number of amendments to elevate the protection of privacy. The key points are:
1. How long tin yous handle Customer Due Diligence (CDD) information for: the fourth dimension boundary for belongings information is 5 years as well as later on that catamenia yous must delete the data. However, yous may live able to retain information for a farther 5 years: this possibility depends on Member State legislation as well as justified on a case-by-case ground (Article twoscore of the AMLD).
2. Informing clients almost how the information may live used: the novel clients take away hold to live informed of the possible occupation of their personal information for coin laundering prevention purposes earlier establishing a concern relationship.
3. Only using information for the purpose for which it was obtained: you should solely occupation information for the master purpose as well as non for whatsoever other purpose, without consent.
4. It has been made clear that information can’t live used for commercial purposes.
A positive feeling on the observe of information comes also from the co-rapporteur Judith Sargentini who said “we cleaned upward the information protection […]. So nosotros made sure that the information subject, the somebody who wants to know something – perchance they take away hold a feeling that something went incorrect amongst their information – has rights to redress, without tipping off criminals, but they take away hold the right to redress. We observe information memory rules.”.
Besides, Věra Jourová – equally fellow member of the Commission as well as responsible for the information protection reform, going to supersede 28 national regimes yesteryear 1 strong pan-European regime for protection of personal information – added: “speaking almost information protection inwards relation to the Anti-Money Laundering Directive as well as related things inwards the novel legislation, I tin say that nosotros pay really high attending to protecting fundamental rights as well as specially the right to privacy as well as the right to the protection of personal data. These 2 pieces of legislation are really compatible as well as they tin piece of work together really good when they are introduced inwards practice.”.
8. The touching on legal professions…
Certainly lawyers are involved inwards many activities which are vulnerable to coin laundering, such as: a) occupation of client accounts; b) buy of existent estate; c) creation as well as administration of trusts as well as companies. In fact, the implications of this novel legal framework for legal professionals are much improve than the tertiary AML Directive. Indeed, at that spot has been a struggle betwixt law firms (and the legal professions inwards general) as well as the Commission for years on these issues, as well as at nowadays most of the provisions of the novel Directive come upward from what the European Court of Justice (as good equally the European Court of Human Rights) has said.
The most of import judgment is Case C-305/05, OBFG v Council. In this case, the Belgian Bar Association alleged that the extension, foreseen inwards the tertiary AMLD, to lawyers of the obligations to inform the competent authorities when they come upward across facts which they know or suspect to live linked to coin laundering as well as to transmit to those authorities additional information which those authorities consider useful, unjustifiably impinges on professional person secrecy as well as the independence of lawyers, principles which are a factor chemical element of the fundamental right of every private to a fair trial as well as to the observe of his rights of defence. So, at the asking of the Belgian Cour d’Arbitrage, the Court of Justice was asked to clarify whether the imposition of those obligations on lawyers infringed the right to a fair trial.
The Court’s ruling, incorporated inwards the 4th AMLD, stated that the obligations of information as well as cooperation apply to lawyers solely inwards so far equally they suggest their client inwards the training or execution of sure transactions essentially of a fiscal nature or concerning existent estate, or when they deed for as well as on behalf of their client inwards whatsoever fiscal or existent estate transaction. As a rule, those activities, yesteryear their really nature, take away hold house inwards a context which has no link to judicial proceedings, as well as consequently, autumn exterior the ambit of the right to a fair trial.
In whatsoever other case, the legal advice is dependent area to professional person secrecy. So, equally shortly equally a lawyer is called upon for assistance inwards defending a client or inwards representing that client earlier the courts, or for advice equally to the mode of instituting or avoiding judicial proceedings, that lawyer is exempt from the obligations of information as well as cooperation, regardless of whether the information has been received or obtained before, during or later on the proceedings. An exemption of that variety safeguards the right of the client to a fair trial.
9. Next priorities…?
As for the adjacent political priorities, sure enough it is quite essential to ensure transposition: the AMLD must live implemented equally shortly equally possible. The European Commission, inwards guild to ensure an effective as well as consistent application of the Directive, volition assist Member States inwards the transposition of the Directive yesteryear organizing workshops as well as clarifying the interpretation of sure provisions.
It is also worthy to cite the new European Agenda on Security 2015-2020, adopted yesteryear the European Commission to back upward improve cooperation betwixt Member States inwards the struggle against terrorism, organised criminal offence as well as cybercrime. In the Agenda, indeed, at that spot is an AML as well as a counter-terrorism dimension, so that it may live possible to take away hold some farther measures on financing. The Agenda mentions specifically preventative measures regarding freezing assets of European Union internal terrorists (Article 75 of the treaty), but also expects some farther initiatives at the international level, specially the mandate of FAFT to ship out a revision of initiatives existing inwards terrorist financing to encounter the effective application of these existing rules as well as to come upward up amongst potential novel initiatives inwards terrorism financing. FATF may nowadays a study inwards Oct this year.