UK Money Laundering Regulations 2026: What Changed for Accountants

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 came into force on 30 June 2026. For accountancy firms they amend the Money Laundering Regulations 2017, the rules that sit behind your customer due diligence, risk assessments and supervision. ICAEW describes the package as 15 targeted changes, and ACCA's guidance for members stresses that many of them clarify existing expectations and do not create new burdens. Even so, a few points are likely to change how your firm documents its work. This guide summarises what the professional bodies have said, what it means in practice, and how to update your procedures. It is general information, not legal advice, so check the regulations themselves and your supervisor's current guidance before you act.

What the 2026 amendments are, in plain terms

Rather than rewriting the regime, the 2026 regulations adjust specific provisions. ICAEW's regulatory news from August 2026 and ACCA's In Practice article from September 2026 both set out the main themes, and the accountancy bodies' joint guidance group, CCAB, has updated its sector guidance to reflect them. The changes that matter most to a practising firm fall into six areas, covered below.

1. Enhanced due diligence triggers

The trigger for enhanced due diligence (EDD) on transactions that are "unusually complex or unusually large" is now judged against the sector and the type of transaction. In practice that means you should be able to explain why a transaction is out of the ordinary for that kind of client and that kind of work, rather than applying one fixed yardstick across the firm. Document your reasoning when you decide that EDD is, or is not, needed. Our guide to enhanced due diligence for accountants covers the process step by step.

2. High-risk third countries

For the purposes of the regulations' enhanced measures, high-risk third countries are now those on the Financial Action Task Force (FATF) call-for-action list. According to the FATF's June 2026 update, that list names North Korea, Iran and Myanmar. Do not treat that as the end of your geographic risk assessment. Professional bodies point out that firms should not rely on the list alone, because clients and transactions linked to other jurisdictions can carry real risk. Check FATF's current statement before you rely on this list, as it is updated several times a year.

3. Thresholds in pounds, not euros

Several monetary thresholds that were previously expressed in euros are now expressed in pounds sterling. If your onboarding forms, cash policies or monitoring rules still refer to euro amounts, they need updating. Take the new figures directly from the regulations or your supervisor's guidance and not from older templates, and record the date you changed them.

4. Company formation work is now clearly within scope

Selling off-the-shelf companies is now a regulated trust or company service provider (TCSP) activity. If your firm sells shelf companies as an add-on to client work, you should check that your supervision registration and your policies reflect that. Even if you have been treating this as covered, record the decision so you can show your reasoning on inspection.

5. Source of funds and beneficial ownership evidence

Source of funds checks are now aimed at transactions that look inconsistent with what you know about the client, rather than being applied in the same way to everything. The updated CCAB guidance also sets out an order of preference for evidence of beneficial ownership, with a passport preferred where it is available. Our guide to ultimate beneficial ownership for accountants explains how to trace and record ownership, and you should align your file notes with the CCAB hierarchy.

6. Electronic identity verification

If you use a digital identity provider, the amendments and the related guidance say that a provider not certified under the UK digital verification services (DVS) trust framework should not be relied on alone. Responsibility for this sits with the person in charge of the firm's anti-money laundering (AML) compliance, usually the money laundering reporting officer (MLRO). Our guide to the MLRO role in an accountancy firm sets out those duties. Ask your provider whether it is certified, and if it is not, add a second check.

An action list for your firm

ACCA's guidance suggests a practical set of steps, which we have adapted into a checklist:

1. Review your policies, controls and procedures. Compare them with the amended regulations and the updated CCAB guidance, and note what changed.
2. Update every sterling threshold. Search your templates, forms and monitoring rules for euro figures.
3. Check your TCSP scope. Confirm whether you sell shelf companies and, if so, that your registration and risk assessment cover it.
4. Document your EDD reasoning. Keep a short note of why a transaction was or was not treated as unusually complex or large.
5. Check your electronic verification. Confirm whether your provider is DVS certified and who in the firm is accountable for that decision.
6. Update training. Brief everyone who works on client onboarding or monitoring, and keep a record of attendance.

Our CPD courses can help you build that training, and our AML and KYC guides hub links to related guides.

What about your existing risk assessment?

Your firm-wide risk assessment should be reviewed after any change to the regulations, not just when the calendar says so. Read it with the six themes above in mind and record that you did so, even if you conclude that no change is needed. A short dated note showing that you considered the amendments is easy to produce and valuable if your supervisor asks.

Frequently asked questions

When did the 2026 amendments come into force?

On 30 June 2026, according to the professional bodies' guidance.

Do the amendments create lots of new obligations?

ICAEW describes 15 targeted changes, and ACCA says many clarify existing expectations. Some, such as the move from euro to sterling thresholds and the TCSP scope point, will still need action.

Which countries count as high-risk third countries?

For the regulations' enhanced measures, those on the FATF call-for-action list, which in June 2026 named North Korea, Iran and Myanmar. Check the current list.

Can I rely on any digital identity checking tool?

Not on its own if the provider is not certified under the UK DVS trust framework. Add a second check and record who made the decision.

Who should lead the update in a small firm?

Usually the MLRO or the partner responsible for AML compliance, with a short written record of what was reviewed and changed.