EU AML Regulations 2027

Risk and ongoing monitoring

AMLR 2024 vs 4/5 AMLD

[Updated October 2026]

Key differences in Risk and ongoing monitoring under AMLR.

 The EU Anti-Money Laundering Regulation (AMLR) makes ongoing monitoring more specific, requiring a view across relevant group relationships and client information updates at least annually for higher-risk clients and every five years for others, with earlier reviews where needed. It expressly requires examination of the origin and destination of funds for complex or unusual transactions, differentiates country-related enhanced due diligence and expands specified PEP coverage. Sanctions checks become an explicit part of CDD, while additional measures apply to qualifying services for wealthy clients.

Ref: AMLR Articles 2, 9–10, 16, 20, 25–31, 34 and 42–46.

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Understand what AMLR changes for EU law firms, with links to legislation and local guidance, plus UK-specific comparisons for firms with offices there.


EU level

AMLA: regulatory instruments – tracks every guideline and technical standard as it's finalise

AMLA: draft regulatory technical standards (RTS)

AMLA: public consultations – draft guidance open for comment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