PEPs under AMLR, Regulation (EU) 2024/1624 vs UK MLR2017
What UK law firms need to know
[Updated August 2026]
PEP comparisons for UK law firms with EU offices
In short, the UK and EU are moving in opposite directions. The UK has relaxed its approach to domestic PEPs following FCA July 2025 guidance, treating them as lower risk and encouraging early declassification. The EU treats domestic and foreign PEPs identically: full EDD applies regardless of nationality, with a hard 12-month minimum after leaving office.
The EU definition is also broader; it explicitly captures heads of regional and local authorities with constituencies of 50,000 or more, and adds siblings of heads of state and government as family members in scope.
Ref:
UK: MLRs 2017, Reg 35.
EU: Regulation (EU) 2024/1624, Art 2(1)(34)–(36), Arts 20(1)(g), 42–46.
UK MLRs
EU AMLR
Operational implication
Domestic and foreign PEPs
Domestic PEPs have a lower-risk starting presumption than non-domestic PEPs. If there are no other high-risk factors, less extensive EDD can be applied. Foreign PEPs require enhanced CDD including senior management approval, SoW/SoF and enhanced ongoing monitoring.
All PEPs (domestic and foreign) require enhanced CDD including senior management approval, SoW/SoF and enhanced ongoing monitoring
Jurisdiction-specific PEP workflows may be required to account for different treatment. Screening and case-management systems also need to preserve whether a PEP is domestic or foreign and route the case accordingly.
Regional/local officials
Not explicitly defined; captured by broad "prominent public functions" definition
Expressly includes heads of regional / local authorities with ≥50,000 inhabitants and certain political-party governing-body members representing ≥50,000 inhabitants. Member States may set lower thresholds.
PEP screening scope may need to vary by jurisdiction to capture the EU’s 50,000-inhabitant threshold and any lower national thresholds. Screening providers will need to support that level of population- and role-based filtering.
Family members
Parents, spouse / civil partner; children and their spouses
Parents, spouse / civil partner, children and their spouses. Siblings also included for heads of state, government and ministers
Screening and client data may need to capture the precise family relationship and the PEP’s function, rather than a generic “PEP family member” flag, so EU sibling rules can be applied correctly.
Close associates
Defined as joint beneficial owners / close business relations with a PEP, or sole BOs of structures known to have been established for a PEP's benefit.
AMLA guidance pending
To be confirmed once AMLA guidance is released.
Former PEPs
PEP measures continue for at least 12 months and longer where the firm considers this appropriate to address continuing risk.
PEP measures continue for minimum 12 months, firms must consider continuing risk and apply one or more EDD measures until that risk no longer exists.
PEP status needs more than a simple active/inactive flag. Systems may need to retain the date the function ended, residual-risk assessment and ongoing EDD period so treatment does not stop automatically after 12 months.
Former PEP family and associates
Once the individual leaves office, the continuing former-PEP requirements no longer have to be applied to their family members or close associates.
Even after the PEP leaves office, the former-PEP measures still apply to family members and known close associates.
Declassification logic may need to differ between the UK and EU. Connected persons may need to remain linked to the former PEP and subject to continued treatment in EU workflows after UK requirements have expired
Read more about UK MLRs vs EU AMLR
Frequently asked questions
How does the AMLR materially expand who counts as a PEP?
It expressly brings certain regional and local officials into scope at the 50,000-inhabitant threshold, extends family-member coverage to siblings of specified senior PEPs and allows Member States to go further in defined areas.
Can the same PEP classification be used across UK and EU offices?
Not always. The UK gives domestic PEPs a lower-risk starting presumption where no additional enhanced risk factors exist; the AMLR does not make the same domestic / foreign distinction. The same individual can therefore require different treatment depending on the jurisdiction.
Will existing PEP screening data be enough under the AMLR?
Potentially not. EU treatment can depend on the PEP’s function, jurisdiction, population threshold and family relationship, while AMLA will also issue common criteria for identifying close associates. This puts more emphasis on the depth of data supplied by screening providers, not simply whether they return a PEP match.
National PEP function lists haven't been published yet. How do we screen EU matters in the interim?
Use the Article 2(1) definition directly as that's where the actual PEP categories sit. The national lists, once published, just map specific job titles onto those categories; they don't change what counts as a PEP. AMLA is yet to publish guidance on close-associate criteria and PEP risk levels If your screening provider's database hasn't caught up with the expanded definition, especially regional and local officials, document the gap and what you're doing to cover it. Remember; siblings only count as PEP family members for heads of state and heads of government, not for regional officials.
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