United Kingdom reshapes enhanced due diligence rules (MLR 2026)
An amendment to the MLR 2017 narrows EDD to 'unusually complex' transactions and FATF-listed jurisdictions and expands the trust register. AML Radar signal.
- Jurisdiction
- 🇬🇧 United Kingdom
- Authority
- HM Treasury
- Instrument type
- Statutory instrument — amendment to MLR 2017
This is UK law, so it does not directly bind a Polish or EU company. But it sets a direction: narrowing enhanced due diligence to FATF-listed jurisdictions and new obligations around trusts holding UK property matter to firms working with the British market.
In brief
- What: an amendment to the UK AML rules (MLR 2017) — changes to enhanced due diligence and the trust register.
- Who issues it: HM Treasury (United Kingdom).
- Status / timing: laid before Parliament on 25 March 2026; entry into force expected late June / early July 2026, some provisions in 2027 (to be verified).
What changes
The amendment clarifies that enhanced due diligence (EDD) applies to “unusually complex” transactions rather than all “complex” ones. It also narrows the EDD obligation under reg. 33(b) to jurisdictions subject to the FATF Call for Action — currently Iran, North Korea and Myanmar. The Trust Registration Service is expanded to all non-UK trusts holding an interest in UK land acquired before 6 October 2020. The changes also cover pooled client accounts and customer onboarding following a bank insolvency.
Who is affected
Formally: UK obliged entities — banks, money service businesses, lawyers, accountants, estate agents, trust and company service providers (TCSPs) and trustees.
What it means for non-financial firms
This is UK law, so it does not directly bind a Polish or EU company. It is worth reading as a directional indicator, though: regulators increasingly tie enhanced scrutiny to specific high-risk lists (FATF) rather than applying it “just in case”. If you trade with UK partners or your sector touches real estate, the trust-register change may affect your counterparties’ documentation requirements. Regardless of jurisdiction, the starting point is to establish whether you have a sanction screening obligation at all — and the legal basis of sanctions packages is covered here. For the real estate sector the trust angle is especially worth watching.
What’s next
We await publication of the final entry-into-force dates. Full text and legislative status: The Money Laundering and Terrorist Financing (Amendment) Regulations 2026.
AML Radar is an informational monitor, not legal advice. The content is based on publicly available government sources (links above) as of the update date. Facts and dates may change — verify the current status at the source before acting and consult a lawyer where needed.