On 19 July 2018, the Commission brought Greece and Romania before the EU Court of Justice for non-compliance in transposing the 4th Anti-Money Laundering Directive into their national laws. Ireland was also referred to the CJEU because it has only implemented the rules of the 4th Anti-Money Laundering Directive in a very limited way.

The Commission further reported that infringement proceedings are in progress (in different stages of the procedure) against other EU Member States. In total, the Commission opened infringement proceedings against 20 Member States. The majority of them have not communicated the transposition laws to the Commission. Several MS, e.g. Austria, Belgium, France, Slovakia, and Spain, do not seem to have fully implemented the obligations of the Directive. The Commission continues to observe correct implementation by the EU Member States. It may go ahead with infringement proceedings against certain Member States. The 4th Anti-Money Laundering Directive was to be transposed into national law by 26 June 2017.