Sanctions screening under AMLR, Regulation (EU) 2024/1624 vs UK SAMLA / OFSI
What UK law firms need to know
[Updated August 2026]
Sanctions Screening for UK law firms with EU offices
UK and EU firms already need sanctions screening and ongoing monitoring. The main differences are which lists apply, how country risk is classified and how UN designations take effect.
For international firms, the challenge is making sure screening, country-risk logic and monitoring apply the right jurisdictional rules.
Ref:
UK: SAMLA 2018; applicable UK sanctions regulations; MLRs 2017, Regs 18A, 19A, 33
EU: Regulation (EU) 2024/1624, Arts 26(4), 27, 29–31
UK MLRs / SAMLA 2018 / OFSI
EU AMLR
Operational implication
UN sanctions timing
Relevant UN-listed persons can become UK designated persons directly through the applicable sanctions regulations, triggering the normal asset-freeze and sanctions obligations.
Article 27 creates an interim period between publication of the UN designation and its implementation in EU law. During that period firms must record assets held and attempted / completed transactions.
EU sanctions workflows may need an interim UN-list status and record-keeping process before the corresponding EU designation takes effect.
Country sanctions lists
Sanctions/embargoes and proliferation-financing exposure are geographic risk factors. FATF Call for Action countries trigger mandatory EDD; other country risk is assessed case by case.
Weaknesses in implementing UN proliferation-financing sanctions are a country-risk factor. Countries may be classified as high risk, triggering full EDD, or as having compliance weaknesses, triggering country-specific EDD.
Country-risk workflows may need different jurisdictional logic: in the UK, sanctions and proliferation-financing exposure mainly inform the risk assessment unless the country is on the FATF Call for Action list; in the EU, the country classification can directly determine whether full or country-specific EDD applies.
Applicable sanctions lists
UK Sanctions List applies
EU sanctions lists apply.
Screening providers need both UK and EU list coverage, with jurisdiction-specific matching and escalation where designations differ.
Ongoing sanctions monitoring
Expected for new and existing clients, including following list changes or after a significant period, with monitoring proportionate to risk.
Sanctions status must be regularly re-verified at a frequency proportionate to sanctions non-implementation and evasion risk. This sits alongside the normal CDD refresh cycle.
EU workflows may need a separate sanctions re-screening logic alongside CDD refresh, rather than assuming the 1-year/ 3 year / 5-year practical CDD cycle determines screening frequency
Ownership aggregation
>50% ownership/control test applies, but separate designated-person holdings are not generally aggregated unless there is a joint arrangement or control.
>50% ownership applies individually or collectively.
Screening and ownership logic may need different aggregation rules where multiple sanctioned persons hold minority stakes.
Read more about UK MLRs vs EU AMLR
Frequently asked questions
Where could the same client or matter produce a different sanctions outcome?
Differences in UK and EU lists, designation timing and country-risk treatment mean a client cleared in London may not produce the same result in an EU office.
What evidence do we need to show why a sanctions decision was made and was correct for the office that made it?
As UK and EU rules diverge, the firm needs to be able to show not just that screening happened, but which regime applied, what data was used, which rules were applied and why the resulting treatment was appropriate.
How will our current country-risk model likely need to change under AMLR?
It may need to become more granular. The AMLR distinguishes between Call for Action countries, countries with compliance weaknesses and EU-only designations, with different EDD consequences for each. Country-risk models may therefore need to capture not just whether a jurisdiction is high risk, but why it is classified that way and what treatment follows.
What changes should we expect from our screening data providers to ensure we have the right information to apply both regimes properly?
Screening providers will need to provide enough detail around each hit to support jurisdiction-specific treatment; including which UK, EU or UN list triggered the match, the relevant sanctions regime, designation / effective dates and reliable identifiers for resolving the match.
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