Group-wide arrangements
AMLR 2024 vs 4/5 AMLD
[Updated October 2026]
Key differences in group-wide arrangements under AMLR.
The EU Anti-Money Laundering Regulation (AMLR) makes group-wide AML responsibilities more explicit, including information sharing, compliance oversight and arrangements for qualifying networks and partnerships. Each regulated entity remains responsible for its own compliance decisions. AMLA’s draft technical standards specify how information should be shared securely and how firms should respond when local laws prevent compliance, including notifying supervisors and applying additional safeguards.
Ref: AMLR Articles 16–17 and AMLA’s draft group-wide regulatory technical standards.
4/5 AMLD
AMLR 2024
Shared client information
Is allowed for but limited to surface-level KYC data, including sharing relevant CDD and suspicion information. Applied primarily to traditional groups or larger structures sharing common ownership, management, or compliance control, with ambiguity around networks or non-obliged entities
Mandates deep data sharing (transaction logs, raw risk analyses) under parent accountability across an expanded ecosystem (formal groups, networks, partnerships, franchises and related non-obliged members). Requires secure, real-time, traceable data flow on a need-to-know basis - explicitly banning rules that require prior parent approval before sharing. Leaves final responsibility for CDD and compliance decisions strictly with each individual regulated entity.
Group oversight
Requires group-wide AML policies, procedures and controls, alongside management oversight and compliance arrangements.
Specifies group-level responsibilities more closely. The draft RTS require documented responsibilities, reporting lines and regular information exchanges so leadership, compliance and audit can oversee risks, compliance weaknesses and remedial action across the group.
Restrictions on cross-border sharing
Requires groups to notify supervisors and apply additional safeguards where third-country laws blocked compliance. Supervisors could already restrict business, require relationships to end or order operations to close where risks remained unmanaged. Local secrecy laws did not remove these obligations.
Retains these powers, with draft RTS specifying how restrictions must be assessed, reported and addressed. Requires notification without undue delay and within 28 calendar days of identifying sharing restrictions. Sets out safeguards including independent CDD, enhanced audits and sharing the underlying facts behind suspicions where legally permitted. Preserves applicable confidentiality and privilege protections, with restrictions or closure where safeguards prove insufficient.
Third-country legal barriers
Requires parent undertakings to implement additional measures where third-country laws (e.g., banking secrecy, data localisation) restricted compliance, but lacks a prescriptive operational escalation process
Retains this approach, with draft RTS specifying mitigation and escalation measures. These include seeking customer consent where legally permitted and applying risk-based safeguards such as independent CDD elsewhere in the group, enhanced audits and restrictions on activities. Where safeguards remain insufficient, supervisors can require the group to stop transactions, terminate relationships or close operations in the third country.
Read more
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 firms - key differences
AMLR 2024 vs 4/5 AMLD
UK firms - key differences
AMLR 2024 vs UK AMLS
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
Germany
Italy
Luxembourg
Netherlands
Spain
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