Risk and ongoing monitoring
AMLR 2024 vs 4/5 AMLD
[Updated October 2026]
Key differences in Risk and ongoing monitoring under AMLR.
The EU Anti-Money Laundering Regulation (AMLR) makes ongoing monitoring more specific, requiring a view across relevant group relationships and client information updates at least annually for higher-risk clients and every five years for others, with earlier reviews where needed. It expressly requires examination of the origin and destination of funds for complex or unusual transactions, differentiates country-related enhanced due diligence and expands specified PEP coverage. Sanctions checks become an explicit part of CDD, while additional measures apply to qualifying services for wealthy clients.
Ref: AMLR Articles 2, 9–10, 16, 20, 25–31, 34 and 42–46.
4/5 AMLD
AMLR 2024
Shared client view
Group information-sharing duties already applied.
Expressly requires monitoring to consider relevant relationships the client has elsewhere in the group, including with entities outside AML scope. CDD must also cover all products and services within the relationship. Group-sharing provisions specify relevant client, ownership, relationship and suspicion information, subject to safeguards.
Example: A client of the audit practice is also a client of an unregulated consultancy in the same group. Relevant information from the consultancy relationship feeds into the audit practice's monitoring of that client.
Client information updates
Risk-sensitive updates, including when circumstances changed. OCDD cadences were up to the risk appetite of each obliged entity.
Adds maximum intervals of one year for higher-risk clients and five years for others. Relevant changes or newly discovered facts require review and, where appropriate, earlier updates.
Funds and transaction purpose
Had to understand the relationship purpose and examine the background and purpose of complex or unusual transactions.
Expressly identifies the need to understand economic rationale, expected activity, source and destination of funds as information to obtain where necessary. Complex, unusually large, unusual-pattern or apparently purposeless transactions require examination of origin, destination and purpose.
Complex and unusual transactions
Required examination of the background and purpose of complex or unusually large transactions, unusual transaction patterns and transactions without an apparent economic or lawful purpose.
Retains these triggers and expressly requires examination of the origin and destination of funds alongside the transaction’s purpose.
Interpreting complexity remains a practical challenge for firms whose core business involves complex, legitimate work: how should the transaction’s features, the client’s circumstances and the firm’s experience inform a defensible assessment? More guidance is required.
Country related EDD
Entailed an FATF high-risk-country framework with prescribed EDD, alongside broader geographic risk assessment.
Distinguishes significant strategic deficiencies, compliance weaknesses and specific serious threats to the EU. Designations determine whether the listed EDD measures, selected measures and/or countermeasures apply.
Example: A client based in a country on the EU high-risk third country list triggers the mandatory EDD measures. A client in a country identified for compliance weaknesses triggers the specific measures set for that country, not automatically the full set, so a single "high-risk country" flag won't cover both cases.
PEP coverage
Used broad prominent-function and family definitions.
Expressly includes heads of regional / local authorities with at least 50,000 inhabitants, specifies qualifying political-party roles, and includes siblings of heads of state / government, ministers and deputy / assistant ministers. National extensions can apply. Core approval, SoW/SoF and enhanced-monitoring duties continue.
Sanctions controls
Sanctions duties applied separately, while sanctions exposure was an AML risk factor.
Expressly includes sanctions checks within CDD, relevant sanctioned ownership / control, regular rechecking and sanctions-evasion risk assessment. Between UN designation and EU implementation, specified records must capture managed assets and attempted / completed transactions.
Wealthy client services
Private banking and personal asset-holding vehicles were risk factors without these financial thresholds.
Adds measures for higher-risk personalised services handling €5m+ in assets for clients with €50m+ total assets, excluding their private residence. Applies to credit / financial institutions and TCSPs; requires additional SoF information and measures addressing service risks and conflicts. Both thresholds must be met.
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