The Commission is going ahead with infringement proceedings against Member States for not completely implementing the 4th Anti-Money Laundering (AML) Directive (see also eucrim 2/2018, p. 93). All Member States had to comply with the provisions of the Directive by 26 June 2017.

On 8 November 2018, the Commission reported that it referred Luxembourg to the European Court of Justice for only transposing part of the Directive into national law. The Commission proposed that the Court charges a lump sum and daily penalties until Luxembourg takes the necessary action.

Furthermore, the Commission sent a reasoned opinion to Estonia and a letter of formal notice to Denmark for failing to completely transpose the 4th AML Directive. Although these Member States have declared their transposition, the Commission assessed the notified measures and concluded that some provisions are missing. Estonia and Denmark now have two months to respond and take the necessary action. Otherwise, the European Commission may take the next infringement steps, including referral to the CJEU.