EU AML Regulations 2027

Trusts under AMLR, Regulation (EU) 2024/1624 vs UK MLR2017

What UK law firms need to know

[Updated 21 August 2026]

Trust comparisons for UK law firms with EU offices

The core trust parties are broadly the same under both regimes, but the EU goes further on discretionary trusts, multi-layer structures and foreign trusts.

The AMLR expressly covers objects of a power, default takers and legal entities acting as settlor, trustee or protector. It also requires more detailed beneficial ownership records and can require a foreign trust to register before an EU office starts the relationship.

Ref:
UK: Regs 6, 28, 30A,  44–45ZA
EU: Regulation (EU) 2024/1624, Articles 22, 24, 58–60, 62, 64, 67

Frequently asked questions

When does a foreign trust become a matter-opening issue for an EU office?

Under Article 67, a foreign trust within scope must submit its beneficial ownership information to an EU central register before the business relationship starts. The medium-high/high-risk limitation in Article 67(2) applies to foreign legal entities, not foreign trusts. If the trust triggers registration in several Member States, registration in one Member State is sufficient evidence for the others.

How should we deal with a discretionary trust with a very wide beneficiary pool?

The EU rules do not require every conceivable beneficiary to be treated as a UBO from the start. Under Article 60, where beneficiaries have not yet been selected, the objects of the power and default takers must be identified; an object becomes a UBO when selected, while a default taker becomes one if the trustees fail to exercise their discretion. Certain low-risk structures can be recorded by class.

Trust questionnaires may need to be updated to capture the discretionary framework itself, not just named beneficiaries.

Read more about UK MLRs vs EU AMLR

Additional resources

EU level

Cross-border legal profession