On 25 March 2026, HM Treasury laid the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 before Parliament, introducing a set of targeted changes to the UK’s AML framework.
This is not a wholesale rewrite of the Money Laundering Regulations 2017. The changes tighten definitions, correct areas that led to over-compliance, and reinforce a genuinely risk-based approach.
For compliance teams, that still means real work. Policies, systems and training will all need updating.
Download our guide to all of the key changes here.
When will the changes come into force?
The Regulations are subject to the draft affirmative procedure, so they must be approved by Parliament before they are made.
Once made, most provisions are expected to come into force 21 days later.
In practice, that points to an implementation window from May to June 2026, although some areas, particularly crypto-related provisions, will follow separate timelines.
Customer due diligence thresholds move to sterling
All euro thresholds in the MLRs are being converted into pounds. This removes the need for ongoing currency conversions and aligns the regime with UK practice.
- £10,000 becomes the standard trigger across key high-value sectors
- The occasional transaction threshold drops to £800
- E-money limits are restated in pounds
This looks administrative, though it will require updates to policies, systems and training.
A sharper test for enhanced due diligence
The Regulations clarify that EDD is required for:
“unusually complex or unusually large” transactions
This replaces the previous wording, which often led firms to treat any complex transaction as high risk.
The shift matters. Firms will need to show that EDD decisions are based on what is unusual in context, not complexity alone.
Pooled client accounts: clearer rules, not a removal of simplification
One of the most closely watched changes concerns pooled client accounts (PCAs), widely used by law firms and other intermediaries.
Following consultation, the government has retained the ability for banks to apply simplified measures in appropriate cases. At the same time, it has introduced a more structured framework for assessing PCA risk.
Key points include:
- simplified measures remain available where the intermediary is regulated, risk is low, and information can be provided on request
- banks must carry out a clearer risk assessment and document their approach
- PCA holders must provide underlying client information when requested
- disclosures do not breach confidentiality, and legal privilege is explicitly protected
Narrowing of high-risk country triggers
Mandatory EDD based on geography is now limited to FATF “Call for Action” countries.
This removes the automatic trigger for jurisdictions under increased monitoring, though firms must still consider those countries as part of their broader risk assessment.
Trust Registration Service changes
The amendments refine the TRS regime, including:
- changes to the de minimis threshold
- removal of restrictions that previously kept some low-risk trusts on the register
This creates an opportunity for firms to reassess whether certain trusts still need to be registered.
Insolvency onboarding flexibility
A new provision allows banks to delay completing full CDD when onboarding customers from a failed institution, where there is a surge in demand.
This is a narrow, operational measure. It does not change the requirement to complete verification as soon as practicable, and it does not apply to higher-risk customers.
What firms should be doing now
Even before the Regulations formally come into force, firms should be reviewing:
- country-risk frameworks and how EDD is triggered
- transaction monitoring and escalation thresholds
- procedures for pooled client accounts and information requests
- staff understanding of legal privilege and confidentiality boundaries
- trust portfolios against the revised TRS rules
Regulators will expect firms to show how they have interpreted and implemented these changes, not just that they are aware of them.
Download the full guide
These changes matter especially for law firms, financial institutions and anyone dealing with client money or complex structures.
Our full factsheet breaks down each amendment and what it means in practice.
Download the guide to see:
- how the new PCA framework works in detail
- what counts as “unusually complex” in practice
- how TRS changes affect existing structures
- what needs updating in your AML policies and systems
