EU Finally Agrees on Revised Anti-Money Laundering Directive

On October 31, 2001, the European Union published the directive revising it anti-money laundering directive a measure that will have important impact on the evolution of anti-money laundering measures throughout the world. In the preamble the revised directive explains that the European Parliament has expressed concern that the directive more clearly covers the activities of currency exchange offices (?bureaux de change?) and money transmitters (money remittance offices) as well as investment firms and investment services in the security field. In addition, a purpose of the directive is to expand the coverage of predicate offenses, including those applicable to organized crime, to conform to the 1996 revision of the Financial Action Task Force Recommendations, which will facilitate suspicious transaction reporting and international cooperation. The directive imposes new obligations on the reporting of suspicious transactions and related due diligence on non-financial businesses. The inability of the American Bar Association to make substantial changes in its model rules of ethics may make lawyers vulnerable to this quickly changing area. Another sign of the shifting sands is the Eleventh Circuit?s strong opinion, affirming of the money laundering convictions of Michael Abbell and Bill Moran on November 2, 2001.