Five things to update before the MLR 2026 amendments land

The Money Laundering Regulations 2026 amendments come into force on 30 June. Five operational changes apply to law firms, accounting firms, real estate agencies and non-bank finance companies.

Reference legislation amendments

1. Update your EDD policy wording

The enhanced due diligence (EDD) trigger for transaction complexity has changed. The new statutory wording reads: 'unusually complex or unusually large in each case, given the nature of the transaction.'

Two things changed. 

1. ‘Unusually' now qualifies both complexity and size, not just size. A transaction must be unusually complex to trigger EDD on that ground, not merely complex.
2. The phrase 'given the nature of the transaction' adds a contextual benchmark: complexity and size are assessed relative to what is normal for that type of transaction at that firm, not in absolute terms.

A large transaction is routine for a commercial firm but unusual for a residential conveyancer. The test is now explicitly calibrated to that distinction.

What to do before 30 June

1. Update your EDD policy and PCPs to reflect the new statutory language.
2. Review any documented EDD decisions that relied on the old 'complex' trigger and ensure the reasoning would still hold under 'unusually complex, given the nature of the transaction'. 

Supervisors will focus on how firms interpreted the shift, so the rationale in the file matters as much as the policy update.

2. Update your country risk matrix

EDD is now mandatory only for countries subject to a FATF Call for Action. As at 30 June 2026, that means North Korea, Iran and Myanmar only.

FATF grey list countries (those subject to increased monitoring) no longer automatically trigger EDD. They remain a risk factor to weigh in the overall assessment under regulation 33(6)(c), but they do not require mandatory EDD escalation.

What to do before 30 June

1. Check your country risk matrix. If it currently treats any FATF grey list country as a mandatory EDD trigger, update it. 
2. The distinction to document is: Call for Action countries require EDD; grey list countries are a factor in the risk assessment that may or may not lead to EDD depending on the overall risk of the client and/or transaction. 
3. Note also that regulation 39 (reliance on third parties) carries the same change, so any reliance policies referencing 'high-risk third country' need updating to 'FATF call for action country'.

3. Update your CDD transaction thresholds to sterling

All euro-denominated thresholds in the MLRs are replaced with sterling equivalents. Most convert at approximately 1:1, but two thresholds are set below the current euro equivalent to meet FATF recommendations.

Key thresholds now in sterling

• Occasional transaction CDD trigger: was 15,000 euros, now £12,000. At current exchange rates, this is a modest tightening of around £1,000. Firms doing high-value transaction work (conveyancing, commercial finance, art market, high-value dealers) should check their documented CDD triggers are updated to £12,000.
• Lower occasional transaction trigger: was 1,000 euros, now £800. Applies to certain linked transaction monitoring thresholds.
• Letting agent rental trigger: was 10,000 euros, now £10,000. Broadly unchanged in practice.
• High value dealer threshold: was 10,000 euros, now £10,000. Unchanged in practice.

What to do before 30 June

1. Replace any euro thresholds in your policies, PCPs, and onboarding systems with the new sterling figures. 
2. The £12,000 occasional transaction trigger is the most material change for law, real estate, and non-bank finance.

4. Bring off-the-shelf firm sales into your TCSP scope (law and accounting)

The service of selling an off-the-shelf firm is now explicitly within the scope of trust or company service provider (TCSP) activity under regulation 12. An off-the-shelf firm is defined as a firm that either does not carry on business, or carries on business where that is not the main activity of the TCSP selling it.

The sale is also treated as establishing a business relationship, meaning full CDD and ongoing monitoring obligations apply.

What to do before 30 June

1. Law and accounting firms that sell shelf companies or dormant entities as part of company formation or secretarial services should ensure these transactions are treated as in-scope TCSP activity. 
2. If your current intake process does not capture off-the-shelf firm sales as triggering CDD, update it.

5. Trust Registration Service (TRS): two separate obligations (law and accounting)

There are two distinct TRS changes with different deadlines and different operational implications.

New registration obligation for non-UK trusts with pre-2020 UK land (deadline: 1 September 2027)

Non-UK express trusts that acquired an interest in UK land before 6 October 2020 and still held that interest when these regulations came into force must now register on the TRS. Previously, only trusts acquiring UK land on or after 6 October 2020 were required to register.

Private client practices advising offshore trust clients with legacy UK property holdings need to identify whether any unregistered trusts now fall in scope and plan for registration by 1 September 2027.

De minimis exclusion: confirmed thresholds, existing trusts can now deregister (no separate deadline)

A new general exclusion from TRS registration applies to trusts that meet all four conditions: 

1. No UK land interest; 
2. Assets of appreciable worth not exceeding £2,000 in total; 
3. Cumulative property value since creation not exceeding £10,000; and 
4. Income not exceeding £5,000 per annum.

Assets of appreciable worth include works of art, antiques, collectables, jewellery, and other non-financial assets capable of increasing in value.

Importantly, the original restriction limiting this exclusion to new trusts only has been removed. Existing trusts already registered on the TRS that meet these criteria can now be deregistered.

Anti-avoidance note: the exclusion does not apply if the same settlor has already used it for another trust. A settlor cannot claim the de minimis exclusion across multiple trusts.

What to do

Review current TRS registrations for trusts that may now qualify for the de minimis exclusion. 
Identify any non-UK trust clients with UK land acquired before October 2020 and assess whether they need to be brought into the registration process ahead of the September 2027 deadline.