Money Laundering and Terrorist Financing (Amendment) Regulations 2026 – Commencement Update

The majority of the provisions in the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621 came into force on 30 June 2026, 21 days after the instrument was made on 9 June 2026.

These amendments make targeted changes to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, including reforms to customer due diligence, enhanced due diligence, pooled client account requirements, and the supervision of cryptoasset-related activity.

Staggered implementation of cryptoasset provisions

Certain provisions are subject to delayed commencement:

• Enhanced due diligence requirements for specified cryptoasset activities will come into force on 1 February 2027.
• Changes to the cryptoasset change-in-control regime will take effect in full on 25 October 2027, with limited transitional provisions commencing earlier.

These staged commencements are intended to align the amendments with the wider implementation timetable for the UK’s evolving cryptoasset regulatory framework.

Impact on Notaries:

• High-Risk third countries

The definition of ‘high-risk third countries’ is now aligned directly with the lists published by the Financial Actions Task Force (FATF).

Notaries must ensure their screening process refer to the current FATF lists rather than relying on a separate UK List. Enhanced due diligence (EDD) must continue to be applied, where required, for clients or transactions involving jurisdictions identified by the FATF as high-risk.

• Greater emphasis on risk-based judgement

The amendments narrow certain situations where EDD is mandatory and provide more flexibility for notaries to apply proportionate, risk-based measures.

For notaries this means documenting why standard, simplified or enhanced due diligence is appropriate for each matter.

• Unusually complex or large transactions

The regulation sets out the circumstances in which enhanced due diligence is required, particularly in relation to complex or unusually large transactions.

Notaries involved in property, company, trust, or international transactions should update their procedures to ensure such transactions are appropriately risk-assessed, subject to enhanced due diligence where necessary, and supported by clear documentation of the rationale for the level of due diligence applied.

Summary

In summary, the Regulations are now largely in force, with only specific cryptoasset-related provisions remaining subject to deferred commencement dates in 2027.

Notaries that undertake work that fall within the scope of the Money Laundering Regulations are encouraged to familiarise themselves with the new amendments and consider a review of their Firm Wide Risk Assessment, policies, controls and procedure.