The money laundering regulations 2026 are now in force, narrowing enhanced due diligence and adding duties on pooled client accounts. The SRA’s consultation on what firms must tell it, including planned mergers, closes on 17 August. And 920 companies entered expedited strike-off at Companies House in the past year, a figure the regulator now cites in its own risk assessment.
Money laundering regulations 2026 are now in force
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, SI 2026/621, were laid in draft on 25 March under section 55(5)(d) of the Sanctions and Anti-Money Laundering Act 2018, debated in Commons committee on 3 June, and took effect for most purposes at the end of June. A minority of provisions follow in 2027.
Four things matter for legal practices. Enhanced due diligence under regulation 33 is narrowed to jurisdictions subject to a FATF call for action, currently Iran, North Korea and Myanmar, with high-risk third countries redefined on that basis from 30 June. Countries under FATF increased monitoring remain a relevant risk factor under regulation 33(6)(c), so the change removes an automatic trigger rather than a reason for care.
Regulation 33 is also amended so that enhanced due diligence bites on transactions that are unusually complex rather than merely complex, which is aimed at sectors where complexity is routine. Regulations 8, 29 and 37 now require additional measures on pooled client accounts, including understanding the purpose of the account and assessing and mitigating the risk, with customers obliged to keep written records. Thresholds previously expressed in euros are now in sterling, and the Trust Registration Service is extended to non-UK trusts holding UK land acquired before 6 October 2020.
Read the regulations on legislation.gov.uk. We have also covered the transfer of AML supervision to the FCA.
What must firms notify the SRA about?
More than they currently do, if the SRA’s proposals go through. The consultation closes on 17 August 2026 and would introduce a new rule setting out prescribed events that firms must report.
Two are proposed: firms would have to notify the regulator when they start holding or receiving client money, and when they plan to merge with or acquire another firm. The second is the one that changes deal practice, since a notification duty attaching to planned M&A activity brings the SRA into a transaction earlier than it currently arrives.
Existing duties already cover changes to managers, owners and compliance role holders, serious financial difficulty, and changes to the financial services a firm provides. The additions are aimed at moments when a firm’s profile shifts in a way that may indicate risk to clients, which is the pattern the regulator has drawn from recent firm failures.
One point of framing is worth keeping straight. The question of whether senior individuals should carry clearer personal responsibility for client money appears in the SRA’s draft 2026/27 business plan as future work, not in this consultation. What is on the table now is notification.
The SRA has published details of the consultation. See also our note on the return of accountants’ reports under the client money rules.
920 companies struck off as Companies House purge continues
The third progress report on parts 1 to 3 of the Economic Crime and Corporate Transparency Act 2023 records that 920 companies entered expedited strike-off over the past year. That is the mechanism Companies House uses to dissolve companies which have given it false information.
The number has acquired a second life. The SRA quotes it in the revised sectoral risk assessment published on 6 August, under a new emerging risk heading on company registration, and draws a practical warning from it: criminals whose companies have been struck off may still hold the original Companies House documentation and use it to prove their credentials. Firms are told to check that corporate clients are properly and currently listed rather than accepting paperwork a client produces.
For conveyancers and corporate teams the check is cheap and the exposure is not. A company that looks well documented and is no longer on the register is precisely the profile the strike-off power exists to remove.
Read the progress report. Our director identity verification checklist and the November verification deadline cover the related duties.