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On 15 April 2019, HM Treasury published its consultation on the steps the UK Government proposes to take to meet the UK’s expected obligation to transpose the Fifth Anti-Money Laundering Directive (5MLD) into national law. The 5MLD makes a number of changes to the Fourth Anti-Money Laundering Directive which was mentioned in our update last year (see here). In implementing the 5MLD, the UK Government is catering for the scenario where an implementation period…