News
What do the amended MLRs mean for you?
11 June 2026
The draft statutory instrument amending the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) was debated in the Commons on 3 June and passed. This means that the majority of changes are expected to come into force on or around 30 June 2026.
Key points relevant to solicitors:
- Provisions on Pooled Client Accounts (PCSs) in regulation 37 will be retained to make clear that banks may apply a simplified set of controls to a PCA provided that:
- the PCA holder is subject to the MLRs or equivalent regulations overseas
- the business relationship with the PCA-holder presents a low risk of money laundering and terrorist financing
- information on the identity of the underlying customers is available on request to the PCA-holder.
- Firms who are requested to provide such information:
- will not be required to provide information which is legally privileged
- will not in doing so breach any duty of confidentiality or restriction on the disclosure of information.
- The new requirements will only apply to PCAs created after the provisions come into force.
- High-risk third countries under regulation 33(b) and 3A will only be those subject to a Call to Action by the Financial Action Task Force – currently Iran, North Korea and Myanmar.
- Note, though, that being subject to increased monitoring by FATF will continue to be a risk factor under 33(6)(c).
- Enhanced due diligence trigger under 33(1)(f)(i) will now read 'a transaction is unusually complex or unusually large'.
- Amendments to the Trusts Registration Service:
- Trusts exempt from registration will no longer count towards the de minimis limit.
- The start date for the de minimis trust amendments was removed, so existing trusts can now be closed on the Trusts Registration Service.