The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June, and in the main take effect at the end of June. Only the provisions relating to crypto-firms take effect later, at various dates in 2027 when the wider reforms take effect.
As previously reported in FIN, the Regulations make various changes to clarify, modernise or bring consistency to the MLR 2017, including:
- refining due diligence requirements for unusually complex or large transactions and those involving high-risk jurisdictions;
- a new CDD regime for addressing pooled client accounts and onboarding customers following a bank insolvency;
- aligning the crypto regime with the new regulatory regime for crypto and the rest of the MLRs;
- updating currency thresholds from euro to sterling;
- bringing “off the shelf” company sales within the scope of regulated TSCP activity; and
- closing gaps and clarifying elements of the TRS.
HM Treasury received some comments on the draft version of the instrument and made some clarificatory changes as a result.