AMLR 2027: prepare for regular sanctions checks

From 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR) applies to the businesses listed below. If your activity falls within its scope, you will need to meet its requirements for checking customers, reviewing results and keeping records. LexaScan can already help you organise sanctions checks and keep their results.

Applies from 10 July 2027

The later date for professional football clubs and football agents is 10 July 2029. These are the application dates of the regulation; existing AML and sanctions obligations still apply before then.

Read Regulation (EU) 2024/1624 on EUR-Lex

Which businesses need to follow the regulation?

The groups below are covered when they carry out the activities defined in the regulation. Size alone does not exempt a business: the rules can also apply to a small firm or an individual professional.

Which businesses need to follow the regulation?
Business or professional activityApplies from
Banks and credit institutions
Electronic money institutions (EMIs)
Payment institutions (PIs)
Investment firms and certain insurance and other financial institutions

Including life insurance and other investment-related insurance activities within the regulation’s scope.

Crypto-asset service providers (CASPs)
Auditors, external accountants and tax advisers
Lawyers and notaries for specified activities

For example, when assisting with property purchases, company formation or managing client assets.

Trust or company service providers
Real estate agents and other property intermediaries

Property transactions, including letting where the monthly rent is at least €10,000.

Gambling service providers
Crowdfunding service providers and intermediaries
Traders in precious metals, stones, luxury vehicles, yachts, art and other covered goods

Coverage depends on the goods and applicable value thresholds. For art and other cultural goods, the transaction or linked transactions must total at least €10,000; high-value goods are defined in Annex IV.

Professional football clubs and football agents

For clubs, the covered transactions involve investors, sponsors, agents or other intermediaries, and player transfers.

This is an overview of the main business groups. Article 3 gives the full legal list, and Articles 4–6 set out possible exemptions. Check the exact scope for your activity, especially where transaction thresholds or specific services are involved.

Business scope and dates: Articles 2–6 and 90, Annex IV

What does this mean in day-to-day work?

Sanctions lists are constantly changing, so a single check at the start of a business relationship is not enough. You need a clear process for how often you will re-screen, review potential matches, and store the results.

Screen clients and ultimate beneficial owners (UBOs):
Ensure clients are not subject to financial sanctions. If the client is a company, you must also check its ultimate beneficial owners—the individuals who ultimately own or control the business. Identify these individuals first, then include their details in your screening system.
Apply a risk-based approach:
Set screening frequency based on the nature of your business and the specific risk posed by each client. Regulations do not establish a single one-size-fits-all screening interval.
Analyze matches and record results:
A matching name does not automatically mean it is the same person or company. Evaluate the information, make a reasoned decision, and save both the screening results and your assessment rationale.

Note: When a new person or entity is added to sanctions lists, banks and financial institutions must perform an immediate check. Keep in mind that other EU or national legislation may set additional requirements or tighter deadlines.

Customer checks: Articles 20 and 26

How LexaScan already helps

Use the tools already available in LexaScan to make sanctions checks part of your routine, instead of starting again each time.

Schedule regular checks of your list

Upload a list of customers and other people or companies you need to check, then set up recurring screening. LexaScan repeats the checks at your chosen interval.

Available intervals range from daily and weekly to monthly and longer periods. Choose the frequency that fits your risk assessment, and keep your list up to date as customers or their owners change.

Get notified when new results are ready

LexaScan shows a notification when a list screening finishes, with a link to its results. Open the check to review any possible matches.

Your team can record review decisions and comments alongside the results. This helps you keep track of what was checked and how a possible match was handled.

Find past checks when you need them

Screening results are saved in LexaScan, so you can return to earlier checks and see their results and recorded decisions.

When a colleague, auditor or supervisor asks about a past check, you can open the saved result or prepare a PDF report. You do not need to run a new check to find a result you have already saved.

Screening history and PDF reports

LexaScan allows you to conveniently review past screening results and download PDF reports directly into your company’s compliance archive.

Comprehensive history in one place:

Access past screening results alongside your team’s decisions and comments whenever you need to demonstrate what was flagged and how it was evaluated.

PDF report export:

Export screening results to PDF format to store with your internal compliance documentation or easily share with colleagues and auditors via email.

Note: Screening results should be integrated into your company’s document retention policy. Under relevant regulations (e.g., Article 77), customer screening records are typically retained for five years following the end of a business relationship or a one-off transaction, subject to applicable exceptions and additional requirements.

Keeping records: Article 77

Plan your checks before the new rules apply

Start with the customers and owners you need to check, decide how often to repeat the checks, and agree who will review the results. We can walk you through the existing LexaScan tools.

Discuss your checks with LexaScan

LexaScan supports the sanctions-checking part of your work. Your company remains responsible for its risk assessment, customer identification, sanctions decisions and other obligations under the regulation.