UK MLRs vs AMLR 2027
The complete compliance comparison for UK law firms with EU offices
The EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624, known as AMLR) comes into force across all 27 EU member states on 10 July 2027.
Unlike previous EU AML legislation, AMLR is a regulation, not a directive: it applies in identical terms in every member state without national transposition or implementing legislation.
For UK law firms with EU offices, this creates a dual-regime compliance obligation: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) govern UK practice; AMLR governs EU office practice; and the two regimes diverge in ways that affect every stage of the client lifecycle. This guide covers the key areas where UK and EU law differ materially, with a summary comparison for each and links to the full analysis.
MLRs 2017 vs AMLR 2027
The key divergence points between UK MLRs and AMLR, and the operational implications.
UBO threshold
AMLR lowers the ownership threshold to 25% or more and prescribes how indirect ownership and control must be calculated.
Trusts
AMLR requires foreign trusts to register before an EU business relationship starts and applies broader look-through rules where legal entities hold trust roles.
Enhanced CDD
AMLR introduces more mandatory EDD triggers and measures, including country-specific treatment and a new high-wealth TCSP trigger.
PEP treatment
AMLR expands the PEP population, removes the UK’s lower-risk treatment for domestic PEPs and keeps connected persons in scope for longer.
Sanctions
AMLR ties sanctions more directly into CDD and country-risk treatment, while UK and EU lists, designation timing and resulting EDD outcomes can diverge.
Verifications
AMLR narrows the permitted verification routes, sets eIDAS assurance standards for digital ID and requires more prescribed identity data and beneficial owner register checks.
Source of funds and wealth
AMLR is more prescriptive about when SoF / SoW must be obtained and whose wealth and funds need to be evidenced.
Coming soon
Ongoing monitoring
AMLR applies the monitoring obligation to the client relationship, not the matter and prohibits a siloed, periodic-review approach.
Coming soon
High-risk third countries
AMLR creates tiered country treatment: full EDD for Call for Action countries, weakness-specific EDD for Increased Monitoring countries, plus EU-only designations.
Coming soon
Background: the current supervision model
EU AML compliance has historically been governed by a series of directives (AMLD4 in 2015, AMLD5 in 2018) which set minimum standards that member states then transposed into national law. This produced significant variation across the EU. Member states exercised different discretions, applied different thresholds, and set different supervisory standards. A firm operating across multiple EU jurisdictions navigated a patchwork of national implementations rather than a single rulebook.
Why is the current model being replaced?
The European Commission identified the directive-based approach as a structural weakness. Inconsistent national implementation created regulatory arbitrage - firms and illicit actors could exploit differences between member states. High-profile money laundering failures across EU financial institutions demonstrated that minimum-standard directives were insufficient. The Commission's 2020 Action Plan on AML/CFT concluded that a single, directly applicable rulebook was necessary to close the gaps.
Additional resources
Bar associations for common jurisdictions
Belgium
- Orde van Vlaamse Balies – witwaspreventie (Flemish bars)
- AVOCATS.BE – anti-blanchiment (French/German-speaking bars, OBFG).
Belgium has no single national bar, so both apply depending on the bar of registration.
France
Conseil National des Barreaux – LBC-FT,
Germany
Italy
Consiglio Nazionale Forense – Antiriciclaggio.
Luxembourg
Ordre des Avocats du Barreau de Luxembourg – LBC-FT.
Netherlands
Nederlandse Orde van Advocaten – Wwft.
Spain
Abogacía Española – Prevención del Blanqueo de Capitales (OPBA).
EU level
- AMLA: regulatory instruments – tracks every guideline and technical standard as it's finalised
- AMLA: public consultations – draft guidance open for comment
- EUR-Lex: Anti-Money Laundering Regulation (AMLR) – the regulation itself
- EUR-Lex: sixth Anti-Money Laundering Directive (AMLD6) – the directive Member States transpose
Cross-border legal profession
- CCBE: anti-money laundering – guidance written for lawyers specifically, bridging UK and EU frameworks