JMLSG publishes revisions to Part 1 of AML/CFT guidance

The Joint Money Laundering Steering Group (JMLSG) has published revisions to Part I of its Anti-Money Laundering and Counter-Terrorist Financing Guidance, following its June consultation and to reflect changes introduced by the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (the Regulations). The amendments update guidance on a number of technical areas:

• An amendment to reflect the changes to Regulation 19, including clarification of the term "unusually" as used in Regulation 19(4), in the context of policies, controls and procedures for risk mitigation management which must provide for the identification and scrutiny of a case where a transaction is unusually complex or unusually large.
• An amendment to reflect the new provisions of Regulation 30ZA in relation to customers of insolvency banks, which enable credit institutions to permit such customers to open an account and transact from it before customer due diligence measures are fully completed.
• Amended guidance at paragraphs 5.3.94A and 5.3.99 in relation to identity verification and authority verification requirements in relation to persons purporting to act on behalf of a customer or dealing with assets under a power of attorney.
• Minor amendment to remove the specification of a bank account or securities holding in relation to the application of simplified customer due diligence in the context of a pooled account (Regulation 37).
• Various amendments to Annex 5-V which provides guidance on pooled client accounts.

The revisions have been submitted to HM Treasury for ministerial approval.

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