First AML research finds source of funds and wealth is the dominant concern as international firms prepare for EU’s July 2027 reforms.
LONDON, Sept. 7, 2026 /PRNewswire/ — Nearly three-quarters of senior risk professionals at leading UK law firms expect their firms to apply the EU’s forthcoming anti-money laundering standard globally, including in Britain, according to new research from First AML.
First AML surveyed 60 senior risk professionals at the top 160 UK law firms, including 44 from Top 50 firms, ahead of the EU Anti-Money Laundering Regulation (AMLR) taking effect in July 2027.
The research found that 72% intend to apply the higher standard globally and accept a degree of over-compliance in the UK. A further 15% expect to decide case by case, while 13% plan to maintain separate UK and EU compliance flows. None is still deciding.
The findings suggest that large firms are preparing to avoid a regulatory divide between their British and European offices, despite the two operating under different AML regimes.
AMLR will introduce more prescriptive requirements in areas including beneficial ownership, enhanced due diligence, and source of funds and source of wealth. Each establishment must comply with the rules where it operates, but the regulation also introduces group-wide requirements covering risk assessments, policies, controls and information sharing.
Some EU-headed groups may need to extend equivalent standards to branches and subsidiaries in countries with less stringent requirements, including Britain. Other firms are choosing one higher standard to avoid running separate compliance systems across an international business.
“Large firms have largely settled the policy question: most intend to adopt one higher standard across the business,” said Jonny Coleman, Country Manager UK, First AML.
“The challenge now is making that standard work across offices, matters and jurisdictions, empowering them to fulfil the additional obligations and ensuring the process doesn’t leave clients feeling frustrated and confused.”
Source of funds and source of wealth are the main concerns.
Some 57% of respondents identified source of funds and source of wealth as the area of UK–EU divergence most likely to cause their firm pain. The next largest concern, high-risk third countries, was selected by 18%.
Respondents also expect the changes to affect clients:
- 52% anticipate friction when explaining why information is required;
- 43% expect difficulties obtaining source of funds or source of wealth evidence; and
- 40% cite cross-border clients and foreign documents.
Applying an EU-level requirement in Britain could leave clients facing different information requests from different advisers. Firms operating a common standard will also need to prevent separate offices from duplicating requests or reaching different conclusions about the same client.
Complex ownership structures lead firms’ CDD concerns
Entity and beneficial ownership complexity is expected to be the most common CDD challenge, cited by 48% of respondents. 42% selected cross-border verification, while 40% cited the difficulty of resourcing CDD across a large firm.
Beneficial ownership and entity mapping was the technology capability respondents considered most valuable, selected by 38%. Better sharing of previously collected CDD information followed at 18%.
“The challenge is, and always has been, around complex onboardings,” Coleman said. “Firms need to understand complex ownership structures, know what has already been established elsewhere in the business and preserve the evidence behind each decision. That is difficult when client information is divided across matters, offices and systems.”
Under AMLR, an EU office may be able to rely on CDD performed elsewhere, including within its group. The relying office nevertheless retains responsibility and must be able to obtain the underlying information, assess whether it meets the applicable standard and collect anything missing.
Implementation, rather than budget, is holding firms back
Almost every respondent agreed that better technology could improve compliance culture and the adoption of new regulation. But implementation remains difficult.
When asked about barriers to buying more technology, respondents could select multiple options. Procurement and security reviews topped the list at 57%, followed by integration with existing systems at 50%, and the time required to evaluate and implement technology, also at 50%. Budget was selected by 17%.
The findings suggest that firms have settled on their direction but face a substantial implementation programme before July 2027.
About First AML
First AML is an all-in-one AML platform. It powers thousands of compliance experts around the globe to reduce the time and cost burden of complex and international entity KYC. Our enterprise-wide, long term approach to the CDD data lifecycle addresses time and cost challenges while improving the customer experience and minimising reputational and security risks.
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