The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (opens a new window) are now in force, bringing targeted changes to the UK’s anti-money laundering (AML) regime.
For accountants, this is not a comprehensive rewrite of the 2017 AML regulations. However, the amendments should still prompt firms to review their existing policies and procedures against the changes – helping to ensure their firm’s controls remain current, compliant, and effective.
Key changes at a glance
Enhanced due diligence (EDD) is now more targeted: Mandatory EDD now applies to the Financial Action Task Force’s “call for action” countries only, while the “increased monitoring” countries require a risk-based approach, rather than automatic EDD.
Complex transaction wording has been tightened: The revised wording states that EDD should apply where a transaction is “unusually complex or unusually large”. This change is designed to focus scrutiny on unusual transactions that present genuine risks.
Thresholds from euros to sterling: Relevant financial thresholds have been converted into pound sterling, reducing the need for exchange-rate and currency conversion calculations.
Trust and company service work: Sales of “off-the-shelf” companies are expressly brought within scope, and trust registration requirements have been updated. These changes include expanded registration requirements for non-UK trusts holding UK property, while also introducing exemptions for certain trusts. Firms involved in trust work should review these changes and consider whether they affect their existing processes and procedures.
Acting now: what accountants need to do
In light of the changes to the AML regulations, we would suggest that accountancy firms revisit and update their risk assessments, client and matter templates, onboarding checklists, client due diligence and EDD procedures, and training materials.
It’s also important to ensure that staff understand when EDD is required, how to document risk-based decisions, and when to escalate concerns.
For further information on the recent changes and their implications, accountants should visit the ICAEW website (opens a new window), which provides additional detail on the amendments.
To reach out to a member of the team, visit Lockton’s Accountants (opens a new window) page.
