The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 came into force on 30 June 2026. They make amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
For firms, the changes are a prompt to review AML policies, controls, procedures, risk assessments and staff training.
Key changes for Scottish law firms
Scope of work: the list of activities that can bring a legal practice within scope has been expanded to include the sale of an “off-the-shelf” firm.
Enhanced due diligence clarification: references to “complex or unusually large” transactions have been revised to “unusually large or unusually complex”, reinforcing the requirement to focus enhanced scrutiny on transactions that genuinely present elevated risks of money laundering or terrorist financing.
Sterling thresholds: monetary thresholds in the 2017 Regulations have been converted from euros to pounds sterling, removing the need to calculate exchange rates and currency conversions.
High-risk jurisdictions: firms must apply mandatory enhanced due diligence where a client or transaction involves a jurisdiction on the Financial Action Task Force (FATF) “Call for Action” list, rather than all jurisdictions subject to FATF increased monitoring (though identification and assessment of geographical risk is still essential).
Trust Registration Service Framework: changes have been made to the provisions on trusts, so private client and trust teams should check these amendments to ensure existing processes and procedures remain compliant and effective.
What should firms do now?
Scottish solicitor firms should treat the reforms as a practical compliance update. They should revisit their processes, including their practice-wide risk assessments, client and matter risk templates, AML policies, customer due diligence and enhanced due diligence procedures and staff training materials and make changes where required.
Further information
The Law Society of Scotland has published information on the key changes and firms should refer to the Law Society of Scotland’s anti-money laundering web pages for further guidance.