The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 have now been made and will come into force on 30 June 2026. These Regulations amend the Money Laundering Regulations 2017 and introduce targeted changes affecting regulated firms, including legal service providers.
What this means for firms*
Firms must review and update their AML policies, controls and procedures (PCPs) to ensure compliance.
Key changes include:
- Enhanced due diligence (EDD): Required where transactions are unusually complex or large in context
- Pooled accounts: New requirements to understand purpose, assess risks, and maintain written records
- Trust or company service providers (TCSPs): “Off-the-shelf company” sales are now explicitly in scope and treated as business relationships
- Trust Registration Service: Expanded requirements, including certain trusts holding UK land
- Country risk terminology: Introduction of “FATF call for action countries”
- Financial thresholds: Euro thresholds replaced with sterling equivalents
What you should do
By 30 June 2026, firms should have:
- Updated AML policies and procedures
- Revised firm-wide and matter-level risk assessments
- Updated training materials and delivered staff training
Further HM Treasury guidance will be shared when available.
Read the full legislation: The Money Laundering and Terrorist Financing (Amendment) Regulations 2026.
*Please note: Firms regulated by an alternative regulator for example the SRA, should refer to directions received from them on this matter.
