The European Commission has taken Luxembourg to court, asking the European Court of Justice (ECJ) to charge a lump sum as well as daily penalties on the country for transposing only part of the 4th Anti-Money Laundering Directive (Directive 2015/849) into their national law. Without the rules on the freezing and confiscation of proceeds of crime, EU and national law enforcement authorities are unable to stop the proceeds from crime from flowing into the legitimate economy. Financial institutions with operations in Luxembourg should prepare for regulatory developments in light of this case.

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