The Money Laundering & Terrorist Financing (Amendment) Regulations 2026

IPA Insolvency Practitioner newsletter AML Digest, April 2026

Members may recall a recent Government consultation on improving the effectiveness of the Money Laundering Regulations. Following the response to the consultation, these Amendment Regulations have now been laid in Parliament. A copy of the legislation can be found here.

These provisions have not yet come into effect. It is advised that the Commons & Lords will discuss the Regulations in June, and it is expected to be signed into law with the majority of provisions coming into force in late June or early July.

The IPA will issue further communications to members when these changes are taking effect so that members can ensure that policies and procedures remain robust and effective.

The main changes as they affect IPs’ work are expected to be:

• Enhanced Due Diligence (EDD) will only apply to high-risk countries on the FATF black-list
• EDD is refined for complex and large transactions and EDD will only apply to ‘unusually large or unusually complex’ given the nature of the transactions
• The Regulations will also move from the use of € thresholds to £ thresholds (i.e. €10,000 threshold will be a £10,000 threshold).
• If your firm is a Trust or Company Service Provider, the regulations will bring sale of off-the-shelf companies within the scope
• These Regulations make provision in relation to insolvent bank customers. Subject to certain requirements, a credit institution may permit an insolvent bank customer to open an account and transact from it prior to completing Customer Due Diligence (CDD) measures (including EDD measures, where relevant) other than identifying the customer and, if applicable, identifying a person purporting to act on the customer’s behalf (and verifying that such person is authorised so to act).