Delivery, oversight and reporting
AMLR 2024 vs 4/5 AMLD
[Updated October 2026]
Key differences in delivery, oversight and reporting under AMLR.
The EU Anti-Money Laundering Regulation (AMLR) sets more detailed rules for outsourcing and reliance on another entity’s CDD, while keeping responsibility with the regulated firm and reserving certain decisions with it. It introduces specific deadlines for supplying CDD evidence and responding to financial intelligence unit requests, with faster responses possible in urgent cases. Governance requirements specify compliance responsibilities, staff suitability and conflicts more closely, alongside notification requirements for activities in other Member States.
Ref: AMLR Articles 8–13, 16, 18, 48–49 and 69–70.
4/5 AMLD
AMLR 2024
Outsourcing
Outsourcing was recognised without an equivalent detailed EU-wide regime.
Requires advance supervisory notification, written arrangements, provider checks and ongoing oversight. Certain decisions cannot be outsourced, including the client risk profile and relationship acceptance. Restrictions also apply to providers in designated third countries, with a conditional group exception.
Reliance on another entity's CDD
Reliance was permitted, with identification/verification evidence supplied immediately on request.
Expressly requires a written agreement or qualifying group procedure, and provision of necessary information and supporting documents without delay and within five working days. Ultimate responsibility remains with the relying entity.
FIU information requests
Prompt cooperation and information provision, without a uniform five-day response deadline
Specifies five working days, with urgent requests potentially requiring responses in less than 24 hours and justified extensions possible. It also provides for common reporting and transaction-record formats through technical standards.
Governance and staff
Management oversight, compliance arrangements and employee screening were required.
Prescribes management-level and operational compliance responsibilities more closely, with competence / integrity assessments before relevant duties and regularly thereafter. Staff performing AML tasks must disclose close client relationships and be excluded from related compliance work.
Cross-border notifications
No equivalent general notification framework in the AML directive.
AMLR requires notification when starting activities in another Member State, including at least three months before establishing a presence, notification on commencement, and at least one month before planned changes to notified information. Exceptions apply for specified notification or authorisation regimes.
Example: A Dublin firm opening a branch in Amsterdam notifies its home supervisor at least three months beforehand. A firm serving Dutch clients remotely notified as soon as it takes steps to do so.
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