The three most influential AML and sanctions jurisdictions globally each have their own distinct legislative frameworks. In the European Union, the primary AML rules are set out in the Anti-Money Laundering Directives — most recently the 4th AMLD (Directive 2015/849) and 5th AMLD (Directive 2018/843) — which are implemented into national law by each Member State. The EU is also in the process of replacing these directives with a directly applicable EU Regulation (Regulation (EU) 2024/1624, the “AMLR”) and establishing a new EU-level supervisor, the Anti-Money Laundering Authority (AMLA). EU sanctions are imposed through Council Regulations under the Common Foreign and Security Policy (CFSP) framework and are directly binding across all Member States without the need for national implementation. In the United Kingdom, following its departure from the EU, AML obligations are governed by the Proceeds of Crime Act 2002 (POCA) — which establishes the core money laundering offences — and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (known as “the MLRs”), which set out the compliance obligations for businesses. UK sanctions are implemented under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), with individual sanctions regimes set out in separate statutory instruments; the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, is responsible for enforcing UK financial sanctions.
In the United States, the foundational AML statute is the Bank Secrecy Act (BSA) of 1970 — also known as the Currency and Foreign Transactions Reporting Act — which requires financial institutions to assist US government agencies in detecting and preventing money laundering, including through the filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs). The USA PATRIOT Act of 2001 significantly expanded the BSA framework following the September 11 attacks, adding stringent KYC and correspondent banking requirements. Most recently, the Anti-Money Laundering Act of 2020 (AMLA 2020), enacted as part of the National Defense Authorization Act, modernised the US AML framework and introduced new beneficial ownership requirements. US sanctions are administered and enforced by the Office of Foreign Assets Control (OFAC) within the US Department of the Treasury, which operates numerous sanctions programmes targeting specific countries, entities, and individuals.
