AML Compliance Update 2026: What Accountants and Finance Professionals Need to Know

The UK’s anti-money laundering (AML) landscape has shifted significantly. The Economic Crime and Corporate Transparency Act 2023 is now in force, Companies House has new investigative powers, and the PSC register has been overhauled. If your AML procedures haven’t been updated since 2020, they’re no longer fit for purpose.

What Changed: The Economic Crime and Corporate Transparency Act 2023

This is the most significant reform to UK company law and AML regulation in a decade. Key changes in force from 2026:

• Companies House identity verification: All directors and PSCs must verify their identity. Agents filing on behalf of companies must also verify. This is mandatory, not optional.
• Enhanced Companies House powers: The Registrar can now query, reject, and remove information it has reasonable cause to believe is inaccurate. This directly affects the quality of beneficial ownership data your firm relies on.
• Expanded criminal liability: Firms that fail to prevent fraud face criminal liability. The “failure to prevent” offence now covers a broader range of economic crimes.
• Crypto asset seizure powers: Law enforcement can now seize cryptoassets without a conviction, lowering the bar for asset recovery.

PSC Register Overhaul

The Person of Significant Control (PSC) register has been restructured. Annual confirmation statements now require positive confirmation of PSC data—passive submission is no longer acceptable. Discrepancies between what you hold on file and what Companies House shows are now higher risk. Your client due diligence procedures must include verification against the updated register.

What Accountants Must Update Now

Customer Due Diligence (CDD) Procedures

Your CDD procedures need to reflect the new beneficial ownership verification requirements. Enhanced due diligence is now triggered for a wider range of entities and transactions. If you’re relying on pre-2023 templates, update them immediately.

Risk Assessments

Firm-wide risk assessments must be updated to reflect the new legislative environment. The new crypto asset provisions, Companies House verification requirements, and expanded failure-to-prevent offences all create new risk vectors that your assessment must address.

Staff Training

AML training is a legal requirement under the Money Laundering Regulations. All relevant staff must be trained on the 2026 changes—including the new Companies House verification requirements, updated CDD thresholds, and the expanded failure-to-prevent offence. Annual refresher training is the minimum; quarterly updates are better practice.

MLRO Responsibilities

If you’re the Money Laundering Reporting Officer for your firm, you now have additional reporting obligations. Suspicious Activity Reports (SARs) must be filed promptly, and the National Crime Agency has expanded its ability to extend moratoriums on consent SARs.

Penalties for Non-Compliance

The consequences of AML failure are severe. Civil penalties can reach £1 million or 10% of annual turnover (whichever is higher). Criminal prosecution is possible for individuals, not just firms. Professional body sanctions including suspension and removal of practising certificates. Reputational damage that is very difficult to recover from.

Your Action Plan

This quarter: Review and update your firm-wide risk assessment. Audit your CDD procedures against the new requirements. Verify your client data against the updated PSC register. Next quarter: Ensure all relevant staff complete updated AML training. Update your engagement letter templates to reflect new verification obligations. Review your SAR filing procedures with your MLRO.

Learnsignal’s AML CPD course covers the 2026 regulatory changes in full. It’s designed specifically for accountants who need to satisfy annual training requirements and stay ahead of the regulatory curve. Complete your AML CPD at Learnsignal.