Enhanced Due Diligence under AMLR, Regulation (EU) 2024/1624 vs UK MLR2017
What UK law firms need to know
[Updated August 2026]
Enhanced CDD comparisons for UK law firms with EU offices
The EU makes EDD harder to avoid and more prescriptive once particular triggers apply. Firms still have discretion to calibrate EDD to the risk in general higher-risk cases, but the AMLR sets more situations where specific measures, or the full EDD suite, are mandatory. The UK leaves more of that calibration to the firm's risk assessment.
The EU also introduces triggers that have no direct UK equivalent: FATF Increased Monitoring countries attract country-specific mandatory EDD, the EU can independently designate additional third countries and higher-risk TCSP relationships can trigger additional EDD where ≥€5m of assets are handled for a client with ≥€50m in total assets.
Ref:
UK: MLRs 2017, Regs 27–28, 33, 35
EU: Regulation (EU) 2024/1624, Articles 2(1)(34)–(35), 26, 29–34, 41–46
UK MLRs
EU AMLR
Operational implication
Transaction complexity
Mandatory EDD where a transaction is unusually complex or unusually large, given its nature, has an unusual pattern, or no apparent economic / legal purpose. Firms must examine the background and purpose.
Mandatory EDD where a transaction is complex, unusually large, unusual in pattern or lacks apparent economic/lawful purpose. Firms must examine the origin and destination of funds and the purpose.
Matter-risk and EDD workflows may need different EU triggers, evidence fields and processes to capture transaction complexity and the origin and destination of funds as part of the review.
PEP scope and family
PEP definition covers specified national/international prominent public functions. PEP family includes spouse/partner, children and their spouses/partners and parents.
Includes specified national/international prominent public functions as well as heads of regional and local authorities with at least 50,000 inhabitants. For the highest public functions e.g. heads of state/government and ministers, PEP family is the same as the UK plus siblings.
Screening data providers and internal logic may need to support jurisdiction-specific role and population thresholds, precise family relationships, PEP function data and evolving AMLA criteria for close associates.
PEP treatment
Domestic PEPs have a statutory lower-risk starting presumption compared with non-domestic PEPs, absent additional risk factors.
PEPs require senior approval, SoW / SoF and enhanced ongoing monitoring
Jurisdiction-specific PEP workflows may be needed, with data retaining domestic/foreign status and the acting jurisdiction to drive the right level of EDD.
PEP EDD period after leaving office
Risk-based; FCA 2025 guidance encourages proactive declassification
Minimum 12 months after ceasing prominent public function, with risk-based extension beyond that
Declassification needs more than an expiry date: systems should retain role-end dates, residual risk and any continuing measures.
High-risk countries
Mandatory for FATF "Call for Action" list countries (post-January 2024 amendment)
Call for Action countries require full enhanced CDD; Increased Monitoring countries require EDD tailored to the specific country weaknesses; and the EU can independently designate additional third countries where it identifies a specific and serious threat.
EU offices need more than a binary country list. Systems must distinguish full EDD + countermeasures, country-specific EDD based on weaknesses and EU-only designations. They must also update the required measures as Commission designations change.
EDD measures
EDD is risk-based with firms given measures including further identity verification, additional information on the customer/ownership/financial situation, SoF/SoW and increased monitoring.
Proportionate to higher risk measures may include: additional customer/BO information, SoF/SoW, transaction rationale, senior manager approval, enhanced monitoring and, where appropriate, first payment from an account in the customer's name.
Broadly similar architecture, but the AMLR gives EU firms a more codified schedule of EDD measures. EDD workflows need to retain why EDD was triggered, so any trigger-specific mandatory measures are applied alongside risk-based measures.
High-wealth relationships
No specific threshold for individual wealth
Mandatory for company and trust formation services (and credit/financial institutions) servicing higher risk clients with ≥€5m assets handled and ≥€50m total assets
EU TCSP workflows need both assets-handled and total-wealth data to identify the AMLR’s €5m / €50m trigger.
EDD refresh
Enhanced monitoring is required based on the assessed level of risk, with no fixed statutory review interval.
Higher-risk customer CDD information must be updated at intervals of no more than one year.
EU review scheduling needs a hard one-year refresh trigger for higher-risk clients alongside existing risk- and event-based reviews.
Read more about UK MLRs vs EU AMLR
Frequently asked questions
Does the AMLR materially change what counts as a higher-risk relationship?
Yes. The AMLR introduces additional or broader EDD triggers in areas including PEPs, high-risk third countries, complex transactions and certain high-wealth TCSP relationships. This means the same client or matter may not receive the same EDD treatment under the UK and EU regimes.
Is EDD still risk-based under the AMLR?
Yes, but with more prescribed outcomes. For general higher-risk situations, EDD remains proportionate to the risk. For certain triggers, however, the AMLR specifies particular measures, or the full set of enhanced measures, that must be applied.
Does the reason EDD is triggered matter more under the AMLR?
Yes. Under the AMLR, different triggers can lead to different statutory EDD requirements. A Call for Action country, an Increased Monitoring country, a PEP and a complex transaction are not treated as interchangeable forms of “high risk”.
Where are the biggest UK–EU AML differences for international law firms?
The most significant differences are in PEP scope and treatment, country-risk rules, complex transactions, high-wealth relationships and review periods. These can affect both when EDD is triggered and what the legislation requires once it is.
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