Client onboarding and verification
AMLR 2024 vs 4/5 AMLD
[Updated October 2026]
Key differences in client onboarding and verification under AMLR.
AMLR 2024, effective 10 July 2027, makes onboarding requirements more specific: firms must collect a defined set of identity data, follow clearer verification rules and check additional parties in certain transactions. Lower transaction thresholds bring more activity into scope, alongside a new EU cash-payment ceiling.
Ref AMLR articles 19, 20, 22, 23, 80
4/5 AMLD
AMLR 2024
Identity data
General identification requirements, with detail largely set nationally.
Specifies EU-wide minimum required information, including birthplace, nationalities, applicable identification numbers, corporate representatives and nominee status, plus detailed beneficial-owner identification information.
Verification methods
Manual identity verification via certified documents with automated screening for PEPs and sanctions.
Defines document/passport/equivalent and eIDAS routes, including substantial or high assurance for electronic identification means and relevant qualified trust services. Beneficial-owner verification retains a separate reasonable-measures route.
Who needs checking
Client, beneficial-owner and representative checks, without equivalent express rules covering both transaction parties.
AMLR expressly covers both parties for estate agents and sole legal intermediaries, plus natural persons on whose behalf or for whose benefit an activity is conducted. Estate-agent verification follows offer acceptance and must precede funds or property transfer.
Transaction and cash thresholds
€15,000 general occasional-transaction threshold and no general EU cash-payment ceiling.
Lowers the threshold to €10,000, requires identification/verification for occasional cash transactions of €3,000+, and introduces a separate €10,000 cash-payment ceiling. Lower applicable thresholds and national cash limits remain relevant; linked transactions count.
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