The UK's Money Laundering Regulations Were Changed on 30 June. Here's What Moved for Payment Firms.

On 30 June 2026, the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were brought into force. The instrument was made on 9 June, and effect was given 21 days later. The 2017 Money Laundering Regulations, under which every UK money transfer operator and e-money institution is required to operate, are amended by it. Two smaller provisions, both concerning cryptoasset firms, have been staged for 1 February 2027 and 25 October 2027.

Most of the commentary published so far has been written for law firms and accountants. This version is written for a compliance officer at a payment firm: the four changes that affect day-to-day operations are set out below, what the instrument actually states is explained, and the points where the numbers are not what was implied by the press releases are flagged.

The CDD Trigger on Transfers Has Been Lowered to £800

The change was framed as “euro thresholds converted to sterling”, and a simple one-to-one swap was Treasury’s stated intent. For most thresholds, that is what was done: £10,000 was set for high value dealers, art market participants and letting agents; £150 and £50 were set for the e-money exemptions; £2,000 was set for casinos.

Two thresholds were not converted one-to-one, and these are the two that matter most to a remitter:

• Under Regulation 27(1)(b), the duty to apply customer due diligence on an occasional transaction that is a transfer of funds was moved from €1,000 to £800.
• Under Regulation 27(2), the general occasional-transaction trigger was moved from €15,000 to £12,000.

The reason was explained by Treasury in its July 2025 consultation response: a one-to-one conversion was intended “except in specific instances where a one-to-one conversion would create potential non-alignment with FATF-recommended thresholds.” FATF’s own limits are set at USD/EUR 1,000 for wire transfers and 15,000 for occasional transactions, so the UK would have been placed above them by a straight £1,000 and £15,000. The threshold was rounded down instead.

The practical effect is that the line was moved down, not sideways. At any exchange rate seen in the last few years, less than €1,000 is bought by £800, which means transfers in the band from £800 up to roughly £830–£870, depending on the day’s rate, were previously placed under the trigger and are now placed over it. If a platform’s CDD threshold is still keyed to a euro figure, or to £1,000 as a comfortable proxy, it will now be flagged as wrong by the FCA. The linked-transaction wording in regulation 27 was also tightened by the same instrument — it now reads “whether executed in a single operation or in several operations which appear to be linked” — so aggregation logic should be re-checked at the same time.

Why a Straight Conversion Was Rejected

The FATF-alignment reasoning above is worth sitting with for a moment. A regulator-set threshold is not treated as a fixed number by Treasury; it is treated as a number that has to stay below an international reference point as exchange rates drift. That is the same logic a screening or monitoring system has to apply if a threshold is hard-coded in one currency: the number is right only until the exchange rate makes it wrong.

Mandatory Enhanced Due Diligence on Country Grounds Has Been Narrowed to Three Countries

Before 30 June, enhanced due diligence on any customer or transaction linked to a “high-risk third country” was required by regulation 33(1)(b), a definition under which both of FATF’s public lists were pulled in: the jurisdictions subject to a call for action and the jurisdictions under increased monitoring, better known as the black list and the grey list.

“High-risk third country” has been replaced by the amendment with a new defined term, a “FATF call for action country”, meaning a country named on FATF’s list of High-Risk Jurisdictions subject to a Call for Action “as such list has effect from time to time.” That list, restated by FATF on 19 June 2026 without change, comprises the Democratic People’s Republic of Korea, Iran and Myanmar. The reliance provisions in regulation 39 were updated to the same term.

The grey list has therefore been dropped from the mandatory trigger. As of FATF’s June 2026 plenary, it runs to 22 jurisdictions — Bosnia and Herzegovina and Iraq were added, and Algeria and Namibia were removed — and several of the remaining names are live remittance corridors for UK firms.

A Rule Was Replaced With a Judgement

The obligation to assess geographic risk has not been changed. Both FATF lists are still pointed at by regulation 33(6)(c), which lists the sources a firm must take into account when a decision is made about whether a situation presents a higher risk. This was made explicit by Treasury in its response: regulated firms “will continue to be required to apply EDD based on geographic risk factors,” and supervisors have been invited to review their guidance so that the countries identified by the National Risk Assessment as the biggest threats to the UK continue to be weighed by firms. The change is therefore from a rule to a judgement. Where enhanced measures on a grey-listed corridor are quietly dropped without a documented risk assessment behind the decision, the amendment has not been read — it has been misread.

”Complex” Has Become “Unusually Complex”

Enhanced due diligence used to be required by regulation 33(1)(f)(i) on any transaction that was “complex or unusually large.” It now reads “unusually complex or unusually large in each case given the nature of the transaction.” The same words were inserted into regulation 19(4)(a)(i)(aa), which governs what must be covered by policies, controls and procedures, and into the equivalent proliferation-financing provision in regulation 19A.

Treasury’s reasoning was that “complex” was already being read by most firms as “unusually complex,” but not consistently, and that in sectors where nearly every transaction has some structure to it, enhanced due diligence on low-risk business was being produced by the old wording. The trigger on unusually large transactions was deliberately left alone.

For a remitter, the words that do the work are “given the nature of the transaction.” A multi-leg corridor payment through two correspondents is complex in the ordinary sense and is entirely usual for that product. The question now asked by the regulation is whether it is unusual for that customer and that product — a question that monitoring rules and policy wording both need to be able to answer.

Two Smaller Items That Are Easy to Miss

Pooled accounts. New paragraphs (10) to (18), inserted by regulation 15 of the instrument, have been added to regulation 29, applying to any pooled account provided by a credit or financial institution to a customer on or after 30 June 2026. Reasonable measures must be taken by the provider to understand the purpose of the account and how it will be used by the customer, satisfaction must be reached that this is consistent with what is known of the customer’s business and risk profile, and due diligence must be refreshed where it is not. If safeguarded or client-money style accounts are provided by an EMI to agents, brokers or other regulated firms, this provision is aimed at that firm.

Thirty days to correct the record. A new regulation 23(3A) requires the FCA to be told, within 30 days, by an FCA-supervised authorised person when a material change to, or a discovered inaccuracy in, previously provided information occurs. It is a short, unglamorous duty with a clear deadline — exactly the kind that gets missed.

What Should Be Done This Month

1. The CDD threshold on transfers should be reset to £800, and the occasional-transaction line to £12,000 — in the system, not just the manual — and aggregation of linked payments should be re-tested.
2. Country risk should be re-mapped. The three call-for-action countries should be confirmed as the mandatory EDD set, a corridor-by-corridor decision should then be made about the grey list, and the decision should be written down.
3. The EDD trigger in policies should be rewritten using the new wording. The policy is required by regulation 19 to reflect it; a policy that still says “complex” is out of date.
4. If FCA authorisation is held, the 30-day correction duty should be put somewhere it will be seen.
5. If pooled accounts are provided, the purpose-and-use check should be built into onboarding for anything opened after 30 June.

A closing note on direction: the FATF presidency was taken over by the UK in July 2026 for a two-year term, with the risk-based approach and its supervision named as one of three priorities. When this instrument — which removes two blanket triggers and replaces them with judgement — is read alongside that appointment, a consistent message is sent to firms: fewer automatic rules, more expectation that reasoning can be shown. More weight is therefore put on the risk assessment and the audit trail behind each decision than on the rulebook itself.

Screening and cited regulatory answers of exactly this kind are provided by ARGOS, and how the underlying screening pipeline is used without a signup is explained in a companion post.

Sources

• The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, SI 2026/621, legislation.gov.uk. Threshold substitutions are set out in regulation 14 of the instrument; the enhanced due diligence changes are set out in regulations 11, 12 and 19; pooled accounts are addressed in regulation 15; the FCA notification duty is addressed in regulation 13.
• Regulation 27 of the Money Laundering Regulations 2017, as amended, legislation.gov.uk.
• Improving the effectiveness of the Money Laundering Regulations: consultation response, HM Treasury, July 2025. The enhanced due diligence changes are covered in paragraphs 1.46 to 1.58; the currency conversion is covered in paragraphs 3.2 to 3.6.
• High-Risk Jurisdictions subject to a Call for Action, 19 June 2026 and Jurisdictions under Increased Monitoring, 19 June 2026, FATF.

Quotations from the instrument and from HM Treasury’s consultation response are Crown copyright and are reproduced under the Open Government Licence v3.0. FATF list statements are quoted briefly and are attributed to FATF.

This post is a summary of the amendments as they have been read here and does not constitute legal advice. The instrument and supervisor’s guidance should be checked before any control is changed.