The draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026

The draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were laid before UK Parliament, alongside a draft explanatory memorandum. The draft Regulations propose amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) to implement the government's consultation response to its 2024 consultation on improving the effectiveness of the MLRs. The amendments aim to strengthen the UK's anti-money laundering and counterterrorist financing (AML/CTF) regime and ensure maintained compliance with Financial Action Task Force standards.

Following feedback to the technical consultation on the draft Regulations in September 2025, the government has made a number of targeted changes, including:

• Pooled client accounts (PCAs): clarifying that banks may continue to apply a simplified, risk-based approach to PCAs where the PCA holder is: (i) subject to the MLRs or equivalent overseas regimes; (ii) the business relationship with the PCA-holder presents a low risk of money laundering and terrorist financing; and (iii) information on the identity of the underlying customers is available on request to the PCA-holder. Additional clarifications are also made.
• Onboarding of customers following bank insolvency: clarifying: (i) that credit institutions may permit "insolvent bank customers", as defined in the draft Regulations, to open and transact from accounts prior to the completion of customer due diligence measures other than those specified, provided the other safeguards and conditions are applied; and (ii) which specific requirements under Regulation 28 constitute identifying a business customer for the purposes of this measure. Additional simplification amendments are also made.
• Counterparty due diligence requirements for cryptoasset businesses: introducing a nine-month implementation period before cryptoasset businesses are required to carry out counterparty due diligence when entering correspondent relationships.
• Trust Registration Service: (i) removing trusts exempted from registration on the Trust Registration Service as trusts which count towards the de minimis limit; and (ii) removing the start date for the de minimis trusts amendment.

The draft Regulations state that they will come into force on the day after they are made.

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