The Council of Bars and Law Societies of the European Union (CCBE), representing European lawyers through their national bars and law societies, has published its comments on the Commission proposal for a third money laundering Directive. CCBE is concerned about the timing with regard to the implementation of the second money laundering directive and the current proposal for a third directive. It also states that the new proposal violates the fundamental right of lawyer-client confidentiality.
CCBE has numerous concerns and wants the text amended in a way that lawyers should only be subject to reporting obligations when the transaction in question is above € 50,000 in value and is in cash and that it should be the lawyer, and not the state, which should decide when a relationship with a client is to end. Furthermore, the definition of ‘serious crime’ should be changed so that it will lead to a proper harmonisation of the legislation across the EU.
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