MLR Sterling Thresholds 2026: What Changed for Accountants

Until mid-2026, the customer due diligence (CDD) triggers in the Money Laundering Regulations 2017 (MLRs) were written in euros. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (S.I. 2026/621) replaced them with sterling. Most figures were converted one for one, which is easy to miss. Two were not, and one of them affects every relevant person who is not a high value dealer, letting agent, art market participant or casino. This guide sets out the new thresholds in regulation 27, based on the text of the amending regulations and the current version of regulation 27 on legislation.gov.uk. It is general information, not legal advice.

For the wider picture of what else changed, see our overview of the 2026 AML changes for accountants. This article is a reference for the numbers.

When the change took effect

According to regulation 1 of the amending regulations, which were made on 9 June 2026, the general rule is that provisions took effect 21 days after they were made, which is 30 June 2026. The amendments to regulation 27 fall under that general rule. Two other changes have later dates: the new rule on cryptoasset correspondent relationships (regulation 34A) takes effect on 1 February 2027, and most of the new Schedule 6B on cryptoasset changes of control takes effect on 25 October 2027.

The thresholds in regulation 27

Regulation 27 sets out when a relevant person must carry out CDD. The table below combines the old euro wording that the amending regulations removed with the new sterling figures shown in the current text of regulation 27.

The explanatory note to the amending regulations says euro references were converted into sterling at one to one, except where that would risk falling short of the standards of the Financial Action Task Force (FATF). Three of the figures above, the transfer-of-funds trigger, the general occasional transaction trigger and the cryptoasset transfer trigger, are not one-for-one conversions. An analysis published by Better Regulation on 23 July 2026 says the reductions to £800 and £12,000 pull more occasional transactions into scope.

Which threshold matters to accountants

For most accountancy and professional services firms, the relevant trigger is paragraph (2): an occasional transaction of £12,000 or more, whether carried out in a single operation or in several that appear to be linked. The threshold was €15,000. Alongside it, paragraph (1)(b) applies CDD to an occasional transaction that is a transfer of funds above £800. CDD is also required in every case when you establish a business relationship, when you suspect money laundering or terrorist financing, and when you doubt documents or information you obtained earlier, and none of those has a monetary threshold.

The practical point is that these are triggers for occasional transactions, those that are not part of an ongoing business relationship. Many accountancy engagements will create a business relationship from the start, in which case CDD applies regardless of value. Where a firm relies on the occasional transaction threshold for genuinely one-off work, the lower figure means less work will fall below it. How the threshold applies to a particular service is a question for your AML supervisor's current guidance, so check it. Our guide to customer due diligence for accountancy practices covers the CDD process itself.

Linked transactions and wording changes

The amending regulations also changed some wording alongside the figures. In paragraph (7A) (letting agents) the word "occasional" was inserted before "transactions". In paragraph (7C)(a) (art market participants) "occasional" was inserted and the reference to a "series of linked transactions" was replaced with transactions executed "in a single operation or in several operations which appear to be linked". The explanatory note says these changes align the triggers for letting agents and art market participants with those for high value dealers. For sector detail, see our guides for high value dealers and art market participants.

Other euro figures that moved to sterling

Regulation 27 is not the only place. According to the amending regulations, sterling figures also replaced euro figures in regulations 13 and 14 (€10,000 became £10,000), regulation 15 (€1,000 became £1,000), regulation 38 (€150 and €50 became £150 and £50), and regulations 64C and 64G (€1,000 became £800). Better Regulation describes the last two as relating to cryptoasset transfers. Matching amendments were made to Schedule 3A to the Terrorism Act 2000 and Schedule 9 to the Proceeds of Crime Act 2002.

Practical steps

These are our suggestions rather than requirements in the regulations:

• Update your policies and templates. Search your AML policy, CDD forms and engagement letters for euro figures and replace them with the sterling thresholds above.
• Review how you treat one-off work. Decide, and record, when a piece of work is an occasional transaction and when it creates a business relationship.
• Watch linked transactions. The thresholds apply to single and linked operations, so your monitoring should look for related transactions that add up.
• Brief the team. Make sure staff who open new matters know which thresholds apply to the firm's own services, not just the headline figure.
• Re-check the source. Use the current version of regulation 27 on legislation.gov.uk and your supervisor's guidance.

Frequently asked questions

Did every threshold go down?

No. Most were converted at one to one, so the numbers stayed the same but changed currency. The general occasional transaction trigger fell from €15,000 to £12,000, and the transfer-of-funds and cryptoasset transfer triggers fell from €1,000 to £800.

Does the £12,000 threshold apply to high value dealers?

No. Paragraph (2) excludes high value dealers, who have their own cash trigger of £10,000 under paragraph (3).

Do I need CDD below the threshold?

Yes, if you are establishing a business relationship or you suspect money laundering or terrorist financing, because those triggers have no monetary threshold.