EU AML Regulations 2027

High-risk third countries under AMLR Regulation (EU) 2024/1624 vs UK MLR2017

[Updated October 2026]

High-risk third countries comparisons for UK law firms with EU offices

The UK and EU increasingly require different approaches to country risk. The UK’s automatic country-based EDD requirement applies to FATF Call for Action countries, while Increased Monitoring status feeds into the wider risk assessment. The EU AMLR uses a tiered framework, requiring full EDD for countries designated as having significant strategic deficiencies and specified measures for those with compliance weaknesses.

The EU can also make additional designations and impose countermeasures. For cross-border firms, a country flag therefore needs to explain which requirements apply, rather than simply marking the country as high risk. Changes to a country’s classification can also affect existing clients, even where their circumstances have not changed. 

Ref:
UK: Reg 33(1)–(3A), (5)–(7)
EU: Regulation (EU) 2024/1624, Articles 29–32, 34–35 and Annex III

Read more about UK MLRs vs EU AMLR

What should we consider before applying the EU’s country-risk requirements across all our offices, including the UK?

A common approach may simplify oversight, but it can also extend evidence requests, approvals and monitoring to UK cases where those measures are not automatically required. Consider where consistency would reduce complexity and where it would add work without addressing the particular risk. A shared client record can support different jurisdictional requirements without every office following an identical workflow.

 

Where might our existing EDD approach fall short of the EU’s country-specific requirements?

An existing checklist may collect substantial information without addressing the weakness behind a particular EU designation. The useful comparison is between the measures prescribed for that country and what your workflow actually collects, reviews and records. More evidence does not necessarily mean the relevant requirement has been met.

 

What are the less obvious operational consequences of UK and EU country-risk rules diverging?

The same country connection can produce different evidence requests across offices, leaving analysts and clients wondering why. Country-status changes can also affect existing relationships even when the client’s circumstances are unchanged. Teams need to distinguish the legal trigger from the firm’s own risk judgement and explain what prompted an additional request.

What would a country-risk system need to do well to support both regimes without creating more manual work?

It would need to turn country classifications into specific actions for the relevant office, rather than simply display a warning. That means retaining the reason for designation, applicable measures, effective dates and previous classifications, then connecting them to evidence requests, approvals and reviews. It should also help teams find affected existing relationships and see what evidence they already hold before requesting more.

Additional resources

EU level

Cross-border legal profession