The Rest of the World — EU AML Directives, FCPA & UK POCA *(OUTLINE + BULLET BODY)*

US law is heavily tested on the CAMS® exam, but it isn't the whole world — and the exam knows it. The European Union legislates AML through a chain of directives, each numbered higher and reaching further. The United States polices foreign bribery with a law that has nothing "money-laundering" in its title but everything to do with predicate crime — the FCPA. And the United Kingdom built its regime on a single powerful statute, POCA. You don't need to be a lawyer in three jurisdictions. You need the headline of each — what it does and the one concept it's famous for. Let's get those headlines.

- EU AML law works through **Directives** — EU-level rules that each **member state transposes** into its own national law (so there's variation in implementation). - **Fourth AML Directive (4AMLD, 2015):** entrenched the **risk-based approach**, required **national and supranational risk assessments**, expanded **PEP** coverage to include **domestic PEPs**, and required member states to set up **central beneficial-ownership registers** for companies and trusts. - **Fifth AML Directive (5AMLD, 2018, applied 2020):** extended AML obligations to **virtual-asset service providers (crypto exchanges and custodian wallet providers)** and **prepaid cards** (lowered thresholds), increased **beneficial-ownership register transparency/access**, and tightened EDD for high-risk third countries. - **Sixth AML Directive (6AMLD, applied 2021):** **harmonized predicate offenses** — listing **22 predicate offenses** for money laundering across the EU — extended **criminal liability to legal persons (companies)**, addressed **aiding/abetting and "self-laundering,"** and raised **minimum penalties** (at least four years' imprisonment for ML). - Memory hook: **4 = risk-based + BO registers + domestic PEPs; 5 = crypto/prepaid + register transparency; 6 = predicate offenses + corporate criminal liability + tougher penalties.**

- The EU created a new **Anti-Money Laundering Authority (AMLA)**, headquartered in **Frankfurt**, to **centralize and strengthen** AML/CFT supervision across the bloc. - Roles: **directly supervise** certain high-risk cross-border financial institutions, **coordinate national supervisors** and FIUs, and promote consistent application of EU AML rules. - Accompanies a shift toward a **single EU AML rulebook (a Regulation)** — directly applicable, reducing the divergence that came from each country transposing directives differently. - Exam cue: "centralized EU AML supervisor, Frankfurt-based" → AMLA.

- Enacted **1977**; targets **foreign bribery and corruption**. Two pillars: - **Anti-bribery provisions:** prohibit offering, paying, promising, or authorizing payment of **anything of value** to a **foreign official** to obtain or retain business or secure an improper advantage. Applies to **issuers, domestic concerns, and certain foreign persons** acting in US territory. - **Books-and-records & internal-controls provisions:** require issuers to keep **accurate books and records** and maintain **adequate internal accounting controls** — so bribes can't be hidden as legitimate expenses. - **Corruption is a predicate offense** for money laundering — proceeds of bribery are "dirty money" that gets laundered. That's why the FCPA sits in an AML curriculum. - Jointly enforced by the **DOJ** (criminal) and the **SEC** (civil, for issuers). **Facilitation payments** have a narrow exception, but anti-bribery exposure remains broad. - Exam cue: "anti-bribery + accurate books and records + internal controls; corruption as predicate" → FCPA.

- **Proceeds of Crime Act 2002 (POCA):** the UK's principal money-laundering statute. Creates the **primary ML offenses** — concealing, arranging, and acquiring/using/possessing criminal property — plus **failure-to-disclose** and **tipping-off** offenses. - POCA uses an **"all-crimes"** approach: laundering the proceeds of **any** criminal conduct is an offense (not limited to a list of predicates). - Suspicious activity is reported via a **Suspicious Activity Report (SAR)** to the **National Crime Agency (NCA)**; institutions can seek a **Defence Against Money Laundering (DAML)** — consent to proceed — before acting on suspect funds. - **Money Laundering Regulations (MLR, current version 2017 as amended):** the UK's **administrative AML rules** — implementing CDD/EDD, risk assessment, record-keeping, and AML-program requirements for regulated firms (the operational layer on top of POCA's criminal offenses). - Regulators include the **FCA**; the **Office for Professional Body AML Supervision (OPBAS)** oversees professional-body supervisors. - Exam cue: "UK criminal ML offenses + all-crimes + report to the NCA" → POCA; "UK CDD/program rules for firms" → MLR.

- **FATF standards** sit on top: the EU Directives, the UK regime, and US law all implement FATF Recommendations (risk-based approach, CDD, BO transparency, the Travel Rule). - **Mutual reinforcement:** EU BO registers (4AMLD) parallel the US CTA registry; UK SARs to the NCA mirror US SARs to FinCEN; FCPA corruption-as-predicate echoes 6AMLD's predicate-offense harmonization. - For the exam, you're being tested on whether you can **place a rule in the right regime** — match the jurisdiction's signature concept to its law.

Here's the global map in one breath. The EU legislates through directives: four brought the risk-based approach and beneficial-ownership registers, five pulled in crypto, six harmonized predicate offenses and added corporate criminal liability — and the new Frankfurt-based AMLA centralizes supervision. The FCPA fights foreign bribery with anti-bribery rules plus accurate books and records, making corruption an AML predicate. And in the UK, POCA defines the criminal money-laundering offenses on an all-crimes basis with SARs going to the National Crime Agency, while the Money Laundering Regulations set the operational program rules. That closes out Domain 2. Next, we begin Domain 3 — building an AML compliance program — starting with its foundation: the pillars of an AML program.