Last reviewed: 22 October 2026. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621) amended the UK Money Laundering Regulations 2017 (MLRs) across most sectors. They followed an HM Treasury consultation that ran from March to June 2024 and drew 224 responses. This guide explains what changed, when each change applies, and what estate and letting agents, accountants, solicitors and financial advisers should do now.
| Date | What happens |
|---|---|
| 9 June 2026 | SI 2026/621 made |
| 30 June 2026 | Most changes in force: sterling thresholds, EDD changes, pooled client accounts, trusts, information sharing, off-the-shelf companies |
| 1 February 2027 | New regulation 34A: enhanced due diligence for cryptoasset correspondent relationships |
| 25 October 2027 | Remaining change-in-control provisions for registered cryptoasset businesses |
If you are not a cryptoasset business, every change that affects you is already in force.
The amendment replaced the euro amounts in customer due diligence triggers with sterling. HM Treasury’s explanatory memorandum describes a “one-to-one conversion except where that would risk misalignment with FATF standards”, which is why two figures fell rather than converting at face value.
| Trigger (MLR regulation 27 and 13) | Before | From 30 June 2026 |
|---|---|---|
| Occasional transactions (most regulated firms) | 15,000 euros | £12,000 |
| Occasional transfers of funds | over 1,000 euros | over £800 |
| High value dealers, cash transactions | 10,000 euros | £10,000 |
| Letting agents, monthly rent | 10,000 euros | £10,000 |
| Art market participants | 10,000 euros | £10,000 |
| Casinos | 2,000 euros | £2,000 |
The rules on linked transactions are unchanged: several payments that appear to be linked still count together towards the threshold. For letting agents, the £10,000 monthly rent test also defines whether the work is in scope at all. See our guide to AML checks for letting agents.
Regulation 33 lists when enhanced due diligence is mandatory. Two triggers changed:
Do not read this as permission to drop EDD. Regulation 33 still requires EDD in any case your own risk assessment identifies as high risk, and in any other case that by its nature presents a higher risk. A client linked to a grey-list country, or a structure you cannot explain, can still call for EDD. The other mandatory triggers, such as politically exposed persons, are unchanged.
Pooled client accounts are bank accounts that a firm, such as a solicitor or letting agent, holds for its clients’ money. The amendment changes the duties of the banks that provide them: they must understand how the account is used, assess and manage the risk, and keep records, and account holders must provide information on request.
Most consultation responses came from the legal sector on this point. The final rules clarify that an account holder does not have to provide legally privileged information, and that a disclosure does not breach a legal adviser’s duty of confidentiality. In practice, expect your bank to ask more about who you hold money for and why.
Every regulated firm should update its policies, checklists and staff training to remove euro thresholds and the old “high-risk third country” wording, then review open matters against the new EDD triggers. Beyond that:
AML Buddy’s checks screen clients against sanctions, PEP and adverse media sources and re-screen them daily, so a change in a client’s risk shows up between transactions. Each check produces a timestamped report you can keep as evidence of the due diligence you applied. You pay per check with no subscription; see pricing. AML Buddy supports your checks; your firm remains responsible for its own risk assessment and decisions under the MLRs.
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621) were made on 9 June 2026. Most changes came into force on 30 June 2026. Two cryptoasset provisions follow on 1 February 2027 and 25 October 2027.
Enhanced due diligence is now mandatory only where a party is established in a FATF call-for-action country. If your own risk assessment shows a higher risk, for example a link to a grey-list country, you must still apply enhanced due diligence.
For most regulated businesses, customer due diligence applies to occasional transactions of £12,000 or more, replacing the previous 15,000 euros. High value dealers apply it to cash transactions of £10,000 or more.
The 2026 amendment itself does not mention digital identity. Separately, HMRC's guidance (updated 13 October 2026) says digital verification services certified against the UK digital verification services trust framework and listed on the DVS register are a reliable and independent source, and that a provider not on the register cannot reliably be deemed suitable. Electronic checks remain optional; document checks are still allowed.
Yes, review them. References to high-risk third countries, complex transactions and euro thresholds in your policies, checklists and training should now reflect the amended wording.
