Pooled Accounts: New AML Duties from 30 June 2026

If your firm holds client money in a pooled account at a bank, a new set of duties took effect for accounts provided on or after 30 June 2026. They come from the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (S.I. 2026/621), made on 9 June 2026, which insert new paragraphs (10) to (18) into regulation 29 of the Money Laundering Regulations 2017. This guide explains what the legislation says, using the text published on legislation.gov.uk. It is general information, not legal advice, so check the current consolidated regulations and your supervisor's guidance for your own situation.

The amendments sit alongside wider changes covered in our overview of the 2026 amendments to the Money Laundering Regulations and our timeline of UK AML changes for accountants.

What counts as a pooled account

The regulations do not give a long definition. New regulation 29(10) applies where a relevant person provides a customer with a new account "into which monies are pooled". Read plainly, this points to an account in which money belonging to several different people is held together, such as a client account run by a professional firm, though the regulations do not say so in terms. The duties apply only to accounts provided on or after the day the paragraph came into force, which on the dates in the regulations is 30 June 2026 (21 days after the instrument was made). Accounts opened before that date fall outside regulation 29(10) as drafted. Because the term is defined only by that short phrase, ask your bank how it is applying the rules to your account.

Two sets of duties: the account provider and the customer

The new provisions split responsibility. One set falls on the relevant person that provides the account, usually a bank. A second set falls on the customer that holds it, which could be a law firm, accountancy practice or other business holding money for others.

What the account provider must do

Under regulation 29(11), a firm providing a pooled account must:

• take reasonable steps to understand the purpose of the account and how the customer intends to use it
• confirm that the purpose and use fit what it knows about the customer, its business and its risk profile, and carry out updated customer due diligence if it cannot confirm this
• once satisfied, assess the money laundering and terrorist financing risk of the customer's use of the account, and take reasonable steps to manage and mitigate that risk

Regulation 29(12) says that when assessing the risk, the provider must consider, among other things, whether controls should be placed on the account. Regulation 29(13) requires it to be able to show its supervisory authority that its measures are proportionate to the risks. A related change to regulation 37 means the assessment duties can work alongside simplified due diligence, and the explanatory note says the measures for pooled accounts may be adjusted where simplified due diligence applies. The text we reviewed did not set out the specific conditions, so do not assume that simplified due diligence removes the duties.

What the customer must do

Three duties fall directly on the customer holding the pooled account:

• Identify underlying persons on request (regulation 29(14)). If the account provider asks, the customer must give information identifying the people on whose behalf money is held in the account, and any beneficial owners of those people.
• Keep records (regulation 29(15)). The customer must keep accurate, up-to-date written records of all money paid into and out of the account. Records must be kept for five years, starting from the date the customer knows, or has reasonable grounds to believe, that each payment is complete.
• Answer law enforcement requests (regulation 29(16)). On request, the customer must give any law enforcement authority information about itself and about how it manages and uses its pooled account with the provider.

Legal professional privilege and confidentiality

The regulations include protections. A customer does not have to provide information that it could refuse to provide on grounds of legal professional privilege in the High Court (or, in Scotland, confidentiality of communications in the Court of Session). A disclosure made under these provisions does not breach any duty of confidentiality owed by a professional legal adviser to a client, or any other restriction on disclosure. The text we reviewed contained no general exemption for client accounts held by accountants, so accountants should not assume the privilege carve-out applies to them in the same way as to lawyers.

What this could mean for accountancy practices (our suggestions)

The following are our own practical points, not requirements from the regulations:

• Check whether you hold any account that pools client money and when it was opened. Accounts provided from 30 June 2026 are the ones the new paragraphs refer to.
• Expect questions from your bank about why the account exists and how you use it, and keep a short written description of its purpose ready.
• Make sure your ledgers can show, for every payment in and out, whose money it was, so that you could identify the underlying persons if asked.
• Set a retention rule of at least five years from the point each payment is complete, and check it against your existing client money and record retention policies.
• Agree who in the firm answers a request from a bank or a law enforcement authority, and how it is logged.

The customer due diligence your bank applies to your firm follows the same principles that you apply to your own clients. Our guide to customer due diligence and KYC explains those principles, and our post on onboarding business customers under regulation 28 shows how a bank would approach a company or partnership customer.

Frequently asked questions

Do the new rules apply to accounts opened before 30 June 2026?

As drafted, regulation 29(10) applies to a new account provided on or after the day it came into force. Existing accounts opened earlier are outside that paragraph. Banks may still review older accounts for their own reasons.

Does the customer have to hand over client names to the bank?

On request, yes: the customer must give information identifying the persons on whose behalf money is held and any beneficial owners of those persons, subject to the privilege exception described above.

How long must payment records be kept?

Five years, starting from the date the customer knows or has reasonable grounds to believe that each payment is complete.