New AML Regulations 2026: What UK Firms Need to Know 

UK-regulated firms should now review their anti-money laundering frameworks following the introduction of the Money Laundering and Terrorist Financing (Amendment) Regulations 2026. 

The regulations were made on 9 June 2026, with most provisions coming into force on 30 June 2026. They amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, commonly referred to as the Money Laundering Regulations 2017. 

The changes are targeted rather than wholesale, but they affect important areas of AML compliance, including: 

• customer due diligence; 

• enhanced due diligence; 

• high-risk jurisdictions; 

• trust registration requirements; 

• monetary thresholds; 

• pooled client accounts; and 

• trust or company service provider activity. 

For firms subject to the UK AML regime, the key message is clear: policies, procedures, risk assessments, training materials and client onboarding workflows should be reviewed to ensure they reflect the updated requirements. 

What are the Money Laundering and Terrorist Financing Amendment Regulations 2026? 

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 update the existing UK AML framework under the Money Laundering Regulations 2017. 

The amendments are intended to strengthen the regulatory framework while supporting a risk-based and proportionate approach to anti-money laundering and counter-terrorist financing compliance. 

Some provisions are subject to later commencement dates, including certain cryptoasset-related amendments. Firms should therefore check which obligations apply to their specific activities and when those obligations take effect. 

Enhanced due diligence and high-risk jurisdictions 

One of the most important changes relates to enhanced due diligence, commonly referred to as EDD. 

The amendments refine one of the mandatory enhanced due diligence requirements under Regulation 33 of the Money Laundering Regulations 2017. 

Firms are now required to apply mandatory enhanced due diligence where a client or transaction is linked to a jurisdiction on the Financial Action Task Force, or FATF, “Call for Action” list. This replaces the previous position where mandatory EDD applied more broadly to jurisdictions subject to FATF increased monitoring. 

This is an important distinction. 

It does not mean that jurisdictions under FATF increased monitoring should be treated as low risk. Rather, they no longer automatically trigger mandatory EDD under this specific part of Regulation 33. 

Firms must still consider those jurisdictions as part of their wider geographic risk assessment. Enhanced due diligence or additional ongoing monitoring may still be required where the facts of the client, transaction, matter or business relationship indicate a higher risk of money laundering or terrorist financing. 

Firms must also continue to apply enhanced due diligence in all other situations required by Regulation 33. 

Unusually complex or unusually large transactions 

The amendments also clarify that firms must apply enhanced due diligence to transactions that are unusually complex or unusually large, having regard to the nature of the transaction. 

This change reinforces the importance of identifying transactions that may require escalation because of their: 

• size; 

• complexity; 

• structure; 

• apparent lack of commercial rationale; 

• unusual funding route; or 

• connection to higher-risk jurisdictions, sectors or counterparties. 

Client and matter risk assessments should be able to capture these indicators. Staff should also understand when a transaction should be escalated for enhanced review. 

For regulated firms, this is not just a policy issue. It is also an operational issue. Risk indicators need to be visible in onboarding workflows, matter opening processes, transaction monitoring and ongoing client review. 

Off-the-shelf companies and trust or company service providers 

The 2026 AML amendments also bring the sale of off-the-shelf companies within the scope of regulated trust or company service provider activity. 

An off-the-shelf company is typically a pre-formed company that has already been incorporated and can be sold or transferred to a client for immediate use. 

This change means that selling pre-formed companies may trigger AML obligations, including customer due diligence. 

The amendment is intended to close a recognised gap. Dormant, aged or pre-formed corporate vehicles can be misused to disguise control, accelerate corporate layering, obscure beneficial ownership or support illicit activity. 

Firms involved in company formation, company administration, nominee arrangements, registered office services or related corporate services should review whether any part of their activity now falls within the amended scope of regulated trust or company service provider activity. 

Monetary thresholds: moving from euros to sterling 

The amendments also update certain monetary thresholds from euros to sterling. 

Firms should check whether internal AML triggers, transaction monitoring thresholds, client onboarding workflows and policy references still reflect the correct currency and value. 

This is particularly important where firms have legacy AML policies or procedures that still refer to euro-denominated thresholds. 

Areas to review may include: 

• customer due diligence thresholds; 

• occasional transaction thresholds; 

• transaction monitoring triggers; 

• internal escalation thresholds; 

• policy references; 

• training materials; and 

• client onboarding forms. 

Pooled client accounts 

Firms dealing with pooled client accounts should also review whether the amended provisions affect their due diligence approach. 

This may be particularly relevant to legal practices, accountancy firms, fiduciary providers, professional services firms and other regulated businesses that handle client money or interact with pooled account structures. 

Where a firm relies on controls applied by another regulated business, it should ensure that its policies and procedures remain appropriate under the amended regime. 

Trust registration requirements 

The amendments also affect aspects of trust registration requirements. 

Firms that advise on, administer or interact with trust structures should review whether their procedures remain aligned with the updated rules. 

This includes checking: 

• when trust registration obligations arise; 

• who is responsible for confirming compliance; 

• whether trust-related client questionnaires remain accurate; 

• whether onboarding checklists need updating; 

• whether beneficial ownership information is being captured appropriately; and 

• whether staff understand when trust-related matters should be escalated. 

What should firms review following the 2026 AML amendments? 

The 2026 AML amendments are a useful reminder that AML compliance is not static. 

Even targeted regulatory changes can create compliance gaps if internal policies, templates, workflows and training materials are not updated. 

Firms should consider reviewing the following areas: 

AREA	WHAT TO CHECK
Practice-wide risk assessment	Whether geographic, client, transaction and service-line risks reflect the amended regime
AML policies, controls and procedures	Whether references to Regulation 33, enhanced due diligence, high-risk jurisdictions and monetary thresholds are current
Client and matter risk assessments	Whether templates capture unusually large or unusually complex transactions
Customer due diligence processes	Whether CDD requirements are correctly triggered for relevant activities, including off-the-shelf company sales
Enhanced due diligence processes	Whether mandatory EDD triggers and wider risk-based escalation are clearly separated
Staff training materials	Whether relevant staff understand the practical impact of the amendments
Trust registration procedures	Whether trust-related processes reflect the updated requirements
Pooled client account procedures	Whether due diligence expectations remain appropriate
Trust or company service provider activity	Whether company formation, administration or related services are now within scope

Practical next steps for AML compliance teams 

In practical terms, firms should: 

• update AML policies and procedures; 

• refresh practice-wide risk assessments; 

• review client and matter risk assessment templates; 

• check enhanced due diligence escalation criteria; 

• update monetary thresholds and policy references; 

• confirm whether any services now fall within regulated trust or company service provider activity; 

• review trust registration procedures; 

• update relevant staff training materials; and 

• ensure compliance teams and client-facing staff understand the changes. 

The objective is not simply to update policy wording. Firms should ensure that the amended requirements are reflected in day-to-day decision-making, onboarding processes, case escalation, transaction monitoring and ongoing client review. 

How Garancie can support enhanced due diligence 

Garancie Limited supports firms with risk-based enhanced due diligence and financial crime risk reviews. 

Our work includes: 

• corporate structure reviews; 

• beneficial ownership analysis; 

• multi-jurisdictional checks; 

• adverse media and public record research; 

• politically exposed person and sanctions-related risk indicators; 

• source of wealth and source of funds support; 

• risk-based reporting; and 
• clear findings to support internal AML decision-making. 

As the AML regulatory framework continues to evolve, firms need reliable information, structured analysis and proportionate reporting to support confident decision-making.

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Legal disclaimer 

This article is for general information only and does not constitute legal advice. Firms should consider the regulations in light of their own risk profile and, where appropriate, seek legal or regulatory advice.