What is SI 2026/621 and what does it change?

If you’re a regulated business in the UK, there are some updates to our money laundering regulations that you need to know about. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, which is also known as SI 2026/621, was made on 9 June 2026 and most of it came into force on 30 June 2026. 

HM Treasury ran a consultation in 2024 to see if the MLRs were working as intended. The answer was mostly yes. However, it found that some rules created a disproportionate amount of work. Especially compared to the actual protection against money laundering they gave. 

This has led to the first significant set of amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 that have been made in a few years. And it impacts several areas you’re likely to recognise from your day to day compliance work: 

• Unusually complex or unusually large transactions
• FATF call for action countries
• Sterling thresholds
• Pooled accounts
• Off-the-shelf firms
• Trust registration services (TRS)

The changes which are now in place are aimed at sharpening the regime. You can read the regulations in full on legislation.gov.uk, alongside HM Treasury’s explanatory memorandum, which sets out the thinking behind each change if you want more detail.

What does SI 2026/621 change?

Unusually complex or unusually large transactions

The old wording required enhanced due diligence for any transaction that was complex and unusually large, with no apparent economic or legal purpose. 

In some sectors most transactions are complex by nature. So businesses were carrying out EDD by default rather than in just higher-risk cases. Amended wording narrows the mandatory triggers for EDD to three specific scenarios:

• Unusually complex transactions, which is updated wording. Complexity is judged against what’s normal for that client relationship and that type of work.
• Unusually large transactions, which remains unchanged from the previous wording.
• Transactions with no apparent economic or legal purpose, also unchanged.

The practical test is to assess whether the transaction is unusual given the nature of the service, the client relationship and the work you’d normally expect to see. 

For example, a multi-jurisdictional corporate restructure might be entirely normal for a corporate client and not trigger EDD on complexity grounds alone. But the same structure appearing in an otherwise straightforward retail conveyancing matter would be a trigger. 

FATF call for action countries

The new Regulations clarify exactly when country-based EDD is mandatory when it comes to country risk. This risk is split into two categories:

• Countries on the FATF Black List (Call for Action countries) automatically trigger EDD. 
• Countries on the FATF Grey List (Increased Monitoring countries) don’t trigger the automatic requirement, but still need factoring into your wider risk assessment. 

The guidance makes it clear that businesses must keep taking FATF mutual evaluations into account as a relevant geographical risk factor under regulation 33(6)(c). You need to apply EDD wherever you spot a high risk of money laundering, terrorist financing or proliferation financing, whichever list a country sits on.

Sterling thresholds

The Regulations set monetary thresholds for when specific AML obligations kick in. In the original Regulations many of these thresholds were given in euros. This meant that UK businesses working in sterling had to convert figures every time they checked whether a threshold applied.

Several of these euro thresholds have now been replaced with sterling thresholds. If your business still references the old euro figures, those need to be updated.

Pooled accounts

This is quite a big change for legal businesses, accountants and conveyancers, who routinely hold client money. If you operate new pooled or client accounts from 30^th June 2026, you now need to carry out these additional checks on who the underlying money belonged to: 

• Identify the persons on whose behalf monies are held, and where applicable, the beneficial owners of those persons
• Keep records of money paid into and out of the pooled account for five years
• Handle requests from account providers or law enforcement in line with your updated procedures and the relevant privilege and confidentiality protections

Off-the-shelf firms

When a regulated business enters into a business relationship, there are obligations that have to be met, like ongoing monitoring and keeping client due diligence up to date. In the previous version of the Regulations, selling an off-the-shelf company didn’t trigger these obligations.

Selling an off-the-shelf firm is now treated as a business relationship in its own right. If your business provides TCSP services and sells off-the-shelf firms, you’ll now need to apply the same due diligence as you would to any other TCSP service.

Trust registration services 

Originally, some non-UK trusts that held UK land fell outside the scope of registration. These updates bring them into scope, as well as removing some of the inconsistencies in what triggered the requirement to register a trust. 

There are several changes here that apply to you if you do trust or private client work:

• Non-UK express trusts holding UK land acquired before 6 October 2020 are now brought within registration requirements
• A new registration date of 1 September 2027 applies to certain categories of relevant trust
• Stamp Duty Reserve Tax has been removed as an automatic trigger for registration
• New and expanded exclusions have been introduced, including a general low-value exclusion

Trustees and anyone advising on trust or private client matters should check whether a trust that previously sat outside TRS now falls within it, particularly where non-UK trusts and older UK land holdings are involved.

AMLCC updates we’ve made to include these changes

We’ve worked through the platform so that your policies, risk assessments and training now reflects SI 2026/621:

Unusually complex or unusually large transactions: AML policies, controls and procedures (PCPs) and training now use the amended wording from SI 2026/621.

FATF call for action countries: Country risk wording has been updated across AMLCC and in the training to reflect the FATF call for action country trigger.

Sterling thresholds: Relevant threshold wording has been updated throughout the platform to use sterling rather than the old euro figures.

Pooled accounts: Where pooled accounts are relevant, we’ve updated the PCP, risk assessment and training wording to match the new requirements.

Off-the-shelf firms: We’ve prepared a new TCSP service item to reflect the SI 2026/621 update.

Trust registration services (TRS): We’ve updated the trust and TRS wording wherever the AMLCC sector version includes trust questions.

Actions to take now

Review and update your PCPs

Update your business’ AML PCPs so that they reflect the amended SI 2026/621 wording on unusually complex or unusually large transactions, country risk, pooled accounts and sterling thresholds. Republish the document once it’s updated and make sure all your staff read and acknowledge the changes.

Refresh your risk assessment answers

Go through your business risk assessment and client risk assessment questions to spot and change any questions that feature the above changes. Make sure you also update your answers and then reassess your risk to see if the new wording changes your inherent risk.

Complete updated training

Beyond reading this article, make sure your staff and senior management complete training on SI 2026/621 and how it impacts your business. As always, this training should be relevant to their role.

Reflect off-the-shelf firm sales in your services

If your business sells off-the-shelf companies, make sure this is included as a TCSP service in your business services and risk assess it accordingly.

Check your pooled and client account procedures

If your business operates pooled accounts, make sure you have the correct records and information to identify the underlying owners, and that you meet the five year retention requirement.

Review your trust and TRS questions

If you carry out trust or private client work, update and answer any new TRS questions. Make sure you republish your risk assessments and take into account your new risk levels.