By AAT Comment Anti-money laundering MUST READ – AML Evolution: Improving Effectiveness 29 Apr 2026 Parliament is considering changes to the UK MLRs. Here are the key (provisional) changes at a glance, and what it means for you. Changes are underway to improve the overall effectiveness of the UK’s Money Laundering Regulations (MLRs). These changes are about closing loopholes, clarifying expectations, and strengthening the risk‑based approach, not adding new core duties for accountants and bookkeepers. When do the changes take effect? In March 2026, the Money Laundering Regulations Statutory Instrument (SI) was laid before Parliament. It is anticipated that most provisions will come into force 21 days after the SI is made, which is expected to be late June or early July 2026. An accompanying Explanatory Memorandum explains what has changed since the government’s technical consultation. The key points most relevant to accountants are summarised below. Important: These changes remain subject to Parliamentary scrutiny and may still change. We will keep members updated once the SI is finalised and in force. Key changes at a glance Greater oversight of cryptoasset businesses Regulatory oversight of cryptoasset activity is being strengthened, reflecting the growing risks associated with this sector. “Off‑the‑shelf” company sales brought into scope The sale of ready‑made (off‑the‑shelf) companies will now fall within the scope of the MLRs. CDD thresholds move from euros to sterling All thresholds are being converted into pounds sterling, including, an £800 trigger for occasional transactions. This removes ambiguity and aligns thresholds with UK practice. Changes to high‑risk third country definitions Only countries subject to a Financial Action Task Force (FATF) “Call to Action” (black list) will be classed as high‑risk third countries under MLRs. Countries under FATF increased monitoring (grey list) will still remain a risk factor under the MLRs Refinement of enhanced due diligence triggers The EDD trigger under Regulation 33 will move from: “complex or unusually large” to: “unusually complex or unusually large, in each case given the nature of the transaction” This reinforces the need for professional judgement, knowing your clients and a genuinely risk‑based approach. Trusts Registration Service (TRS) changes Trusts that are exempt from registration will no longer count towards the de minimis limit. The planned start date for de minimis trust amendments has been removed, meaning existing trusts can now be closed on the Trusts Registration Service. What does this mean for accountants? The SI does not introduce new core AML duties for accountants or bookkeepers. However, it does clarify expectations, particularly in these areas: ongoing risk assessments, not just at onboarding clear justification for changes in client risk ratings greater emphasis on the quality and consistency of AML processes the ability to show how AML controls operate in practice, not merely that policies exist. As a result AAT, in its role as your AML supervisor, will expect not only documented policies, controls and procedures but clear evidence that your AML framework works effectively in practice. Action you should take now To prepare for the changes: set time aside to review and update your AML policies, controls, and procedures plan staff training so changes can be implemented promptly once the SI is in force ensure your current processes clearly demonstrate how decisions are made and risks are managed. We’ll continue to keep you informed as the legislation progresses. AAT guidance AAT has a range of resources available in the AAT Learning Portal including short bitesize modules on AML, licence compliance, and practice assurance reviews. Log in to your MyAAT Account, go to AAT Lifelong Learning Portal and click on ‘Featured CPD’ on the homepage. Find the relevant CPD bitesize and click the ‘Launch’ button. Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email at [email protected] Future of AML/CTF supervision On 21 October 2025, the Government confirmed that the AML/CTF supervision for accountancy, legal and Trust and Company Service Provider sectors will move to a single professional services supervisor (SPSS), the Financial Conduct Authority. While this is a big shift, implementation is likely to take years. In the meantime, AAT will continue as the AML supervisor for eligible AAT licensed members and carry out our normal responsibilities, including Practice Assurance Reviews and risk assessment activities. Therefore, our members must ensure full compliance with the MLR 2017. Find more on the consultation response here. AAT Comment offers news and opinion on the world of business and finance from the Association of Accounting Technicians.