Focus summary
The UK’s AML rules are shifting towards smarter, risk-based compliance, with new sterling thresholds, narrower EDD triggers, clearer rules for TCSPs, more crypto oversight and tighter reporting expectations. APLYiD explain all.
AML compliance
UK’s AML rules have upgraded — here’s what’s changing and when: By APLYiD
The UK has overhauled its anti-money laundering regulations, with many changes taking effect from 30th June 2026 and further crypto-specific rules following in 2027.
What changed?
Thresholds: euro equivalents are being replaced by sterling thresholds.
EDD: mandatory enhanced due diligence now applies to FATF blacklist countries only.
TCSPs: off-the-shelf company sales are now explicitly within scope.
Crypto: firms face tighter oversight, shell bank restrictions and stronger notification rules.
FCA reporting: material inaccuracies or changes must be reported within 30 days.
The UK has overhauled its anti-money laundering regulations.
This June, Parliament passed the Money Laundering and Terrorist Financing (Amendment) Regulations 2026.
Many changes take effect from 30th June 2026, with a handful of crypto-specific rules following in early 2027. The intent behind the reforms is proportionality: smarter compliance focused on risk.
Proportionate does not mean relaxed. It means doing the right things, done properly, where the risk is real.
Sterling thresholds replace euro equivalents
One of the most practical changes is that euro-denominated thresholds are being replaced with pound sterling equivalents across the board.
The new sterling thresholds include:
- €10,000 becomes £10,000
- Occasional transaction thresholds drop to £800
- Standard verification thresholds align at £12,000
Everything is now expressed in sterling, making the rules cleaner, clearer and easier to apply consistently.
Enhanced due diligence: a narrower trigger
Currently, firms must apply Enhanced Due Diligence to customers from countries on either FATF’s blacklist or grey list.
From 30th June, mandatory EDD applies to FATF blacklist countries only. Grey list countries still carry risk and should be reflected in internal country risk frameworks, but the automatic mandatory trigger is gone.
The shift is towards considered, risk-based judgement rather than reflexive escalation.
There is also an important tweak to the language around EDD triggers. The previous threshold, transactions that were “complex or unusually large”, has been updated to “unusually complex or unusually large”.
One word, but the implications are meaningful. Enhanced checks should now be reserved for transactions that are genuinely atypical for the context, rather than anything that simply looks large on the surface.
Off-the-shelf companies: no ambiguity left
Trust or Company Service Providers, company formation agents and similar businesses should take note.
The sale of off-the-shelf companies is now explicitly within scope of AML regulation. Customer due diligence applies, and the grey area that existed before is gone.
Cryptoasset firms: more oversight
For firms operating in the cryptoasset space, the updates have significant implications.
Customer due diligence requirements have been tightened and aligned with the UK’s broader cryptoasset regulatory framework. Enhanced due diligence provisions have also been added for unusually complex crypto transactions.
Crypto firms should prepare for:
- A formal prohibition on dealing with shell banks from February 2027
- Tighter structural controls
- Stricter ownership change notification requirements to the FCA
These adjustments reflect a sustained tightening of oversight in a sector that has grown significantly faster than the regulatory frameworks around it.
Pooled client accounts: time to formalise
Firms using pooled client accounts must now conduct full risk assessments on them and maintain structured records.
If your PCA arrangements have not been reviewed recently, now is the time.
FCA reporting: 30-day window
Material data inaccuracies or material changes must be reported to the FCA within 30 days of becoming aware of them.
The clock starts when you know, not when it is convenient.
Regulated businesses need a clear process for identifying, escalating and reporting material FCA data changes within the required timeframe.
Supervision: the FCA takes the lead
Alongside the regulatory changes, AML supervision of professional services firms is moving to the FCA from professional body supervisors such as ICAEW.
The aim is more consistent oversight and a clearer line of accountability. For firms currently supervised by a professional body, the practical message is the same as it has always been: stay focused on compliance with the regulations, whoever your supervisor is.
UK’s ML/TF Regulations 2026 timeline
30th June / early July 2026
Sterling thresholds, narrower EDD triggers, the grey list change, TCSP requirements for off-the-shelf companies and the FCA 30-day reporting rule.
February 2027
Ban on crypto firms dealing with shell banks and tighter structural controls.
October 2027
Further cryptoasset controls take full effect.
What regulated businesses need to do
- Update EDD procedures to apply mandatory EDD to FATF blacklist countries only, and revisit internal country risk classifications.
- Adjust transaction monitoring to focus on “unusually complex or unusually large”, not just anything that exceeds a size threshold.
- Update systems and policies to reflect the new sterling thresholds.
- If you are a TCSP, ensure CDD applies when selling off-the-shelf companies.
- If you operate in cryptoassets, begin preparing for the February 2027 requirements now.
- Review pooled client account arrangements and ensure formal risk assessments and records are in place.
- Verify FCA data is accurate and make sure there is a clear process for flagging material changes within 30 days.
The direction is clear: less compliance overhead where it adds little value, more focus where risk is real. - APLYiD
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