On 30 June 2026, the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 came into force, introducing the most significant overhaul of the UK’s anti-money laundering regime since the regulations were first implemented in 2017.

For firms carrying out customer due diligence (CDD), enhanced due diligence (EDD), and screening, this is not a routine tidy-up. It resets several of the triggers and thresholds that due diligence teams rely on daily, and it does so on a staggered timetable running into 2027.

The most significant change concerns high-risk jurisdictions. The previous “high-risk third country” test, which required automatic EDD for jurisdictions on the Financial Action Task Force’s (FATF) high-risk lists, has been replaced by a narrower “FATF Call for Action” test. Mandatory EDD under Regulation 33 now applies only to the three countries currently on FATF’s Call for Action list:

• North Korea
• Iran
• Myanmar

Jurisdictions on FATF’s Increased Monitoring (grey) list remain an important risk factor but no longer trigger automatic EDD. Firms will therefore need to recalibrate their jurisdictional risk assessments and screening frameworks, ensuring that grey-listed countries continue to receive appropriate scrutiny within a risk-based approach.

The regulations also refine EDD requirements in other areas. Enhanced measures are now required for transactions that are unusually complex or unusually large in relation to their nature, rather than any transaction that is merely complex or large. The intention is to reduce unnecessary, blanket application of EDD and focus compliance resources on genuinely exceptional activity.

Elsewhere, the regulations convert most euro-denominated thresholds to pound sterling, largely on a 1:1 basis. However, a handful (including several customer due diligence and cryptoasset transfer thresholds) have been recalibrated rather than converted directly, so firms should check the details rather than assume a simple currency swap. Additional obligations apply to pooled client accounts, requiring firms to understand the purpose of each account and assess and mitigate its money laundering risk, while account holders face new record-keeping duties. The regulations also introduce a framework for “insolvent bank customers,” allowing credit institutions to open accounts and begin transacting before full due diligence is completed, subject to safeguards.

The amendments also extend trust and company service provider obligations by bringing the sale of off-the-shelf companies within scope. At the same time, changes to the Trust Registration Service expand registration requirements for certain pre-2020 land-owning trusts while introducing a de minimis exemption for smaller trusts.

Cryptoasset firms face further changes. A revised enhanced due diligence regime for correspondent relationships comes into effect in February 2027, followed by an updated change-in-control framework that takes full effect in October 2027.

For due diligence practitioners, the practical implications are immediate. Risk-based EDD frameworks should be reassessed against the revised jurisdictional triggers, with FATF grey-listed countries repositioned as a risk factor rather than an automatic EDD requirement. Policies, procedures, case management systems and training materials will require careful review, particularly where financial thresholds have been embedded into existing controls. Firms should also reassess pooled account relationships, trust structures and cryptoasset counterparties, while developing a phased implementation plan that reflects the staggered commencement dates across 2026 and 2027.

FACT’s due diligence and screening teams track legislative and regulatory developments as they happen, translating dense statutory instruments into practical guidance for KYC, enhanced due diligence, and investment migration screening. Our jurisdictional risk assessments are updated to reflect the current FATF Call for Action list and the UK’s revised EDD triggers. Our reporting keeps clients ahead of thresholds, registration obligations, and sector-specific requirements as they change.

Whether you need a refreshed due diligence framework, jurisdictional risk analysis, or pre-employment and enhanced screening built around the latest global standards, FACT’s team is ready to help you navigate the 2026 regulations with confidence.

Download our due diligence services brochure from our website to see how we can support your compliance needs.