The Croatian AML Act and the EU 4th Directive

In 1997 Croatia implemented its first broad anti-money laundering Act to bring its procedures and systems in line with international norms. In 2008 this was upgraded in line with the acquis communautaire.

The most recent change is Directive (EU) 2015/849, the 4th EU AML Directive. This has now been implemented into Croatian law, as of January 2018. The key changes include:

  • More demanding due diligence
  • Cash transaction lowered from 105,000 HRK to 75,000 HRK
  • A Politically Exposed Person now includes any physical person who is currently holding, or has held in past 12 months, a prominent public function in a member state or third country, including close family members and associates
  • Lawyers are now subject to AML if involved with financial transactions or real estate
  • An Ultimate Beneficial Owners Register has been set up
  • Stronger sanctions for non-compliance

Not only have these changes brought Croatian law up to speed but it has also tried to include various aspects of best practice from around the world, above and beyond that mandated by the EU.

Given the recent scandals across the continent, it’s good to see at least one country taking money laundering seriously.

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