Upcoming changes to the Money Laundering Regulations

If the SRA’s April update slipped through the cracks during a busy month, here’s your catch-up.

On 22 April 2026, the SRA confirmed that HM Treasury has laid a draft statutory instrument before Parliament proposing amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). Subject to Parliamentary approval, the changes are expected to come into force in late June or early July 2026.

While the instrument remains subject to scrutiny and could yet change, compliance teams should be across the key proposals now.

Pooled client accounts: Clarity, not change

The provisions governing Pooled Client Accounts (PCAs) under Regulation 37 will be retained, confirming that banks may apply simplified controls to a PCA where the account holder is subject to the MLRs (or equivalent overseas regulation), the relationship presents a low risk of money laundering or terrorist financing, and underlying customer identity information is available on request.

Two important protections for firms are built into the proposals: there will be no obligation to disclose legally privileged information, and providing information on request will not constitute a breach of any duty of confidentiality. Crucially, the new requirements will only apply to PCAs created after the provisions come into force -existing arrangements are not affected.

High risk third countries: A narrower trigger

Under the revised Regulation 33, the geographic enhanced due diligence (EDD) trigger will be limited to countries subject to a formal FATF Call to Action — currently Iran, North Korea, and Myanmar. Countries subject to FATF increased monitoring will no longer automatically trigger EDD under this limb, though they will continue to be a relevant risk factor under Regulation 33(6)(c).

Firms should not read this as a relaxation of their broader geographic risk obligations; a robust, risk-based approach to customer due diligence remains essential.

Enhanced due diligence: Refined wording

The EDD trigger under Regulation 33(1)(f)(i) will be updated to read “a transaction is unusually complex or unusually large.” This is a subtle but meaningful refinement in how the threshold is framed, and firms may wish to reflect this language in their updated policies and training materials.

Trusts Registration Service: Two practical updates

There are also changes affecting the Trusts Registration Service. Trusts exempt from registration will no longer count towards the de minimis limit, and the removal of the start date for the de minimis trust amendments means that existing trusts can now be closed on the register where eligible.

Action points

The draft SI may still change before it becomes law, but firms would be well advised to:

• Review the draft statutory instrument and its explanatory memorandum in full
• Begin reviewing AML policies and procedures for any updates required ahead of commencement
• Consider whether internal training will need to reflect the revised EDD and high-risk country wording
• Monitor for Parliamentary approval and the confirmed commencement date

We will provide a further update once the position is confirmed. In the meantime, if you have any questions about how these changes may affect your compliance framework, please don’t hesitate to get in touch.