Update to Anti-Money Laundering Regulations

Article written by David Smith - 17th June 2026

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June. These come into effect automatically 21 days after they were made, so will be in effect as from 30 June.

I wrote briefly about the draft regulations here when they were made available.

By far and away the most crucial and immediate change is that the €10,000 pcm rent threshold for compulsory AML checks for higher value tenancies changes to £10,000. This is quite a change as €10,000 is closer to £8,650 so there is quite a big jump here. This is also quite a key number as there are a fair few rental properties in the higher-end sector that would be picked up by a threshold at £8,500 but not by a threshold at £10,000 so I would anticipate that this will take a reasonable chunk of property out of AML controls and will give agents a lot more flexibility in this area.

The less important change is the new requirements relating to pooled client accounts. These changes are intended to resolve the current impasse in which many banks have become inordinately suspicious of these accounts and are refusing to let some agents have them or being very difficult about it. This has created massive issues for HMRC as a lot of letting agents have registered with them (even though they do not need to do so) in order to satisfy a bank of their anti money-laundering credentials. This then consumes a lot of HMRC resources to process those applications and monitor these firms, even though it is entirely unnecessary.

The pooled client account amendments (which are slotted into regulation 29) require a financial institution to seek to understand a pooled client account and how it is to be used and then carry out an appropriate assessment of the relevant risk and then look at what controls are required to mitigate those risks. I have said that this is the less important change. I am sure that some agents, who have had trouble with getting a pooled client account, will think this really matters. And in principle they are right. But it only matters if banks actually implement the changes in practice and I very much doubt that they will do so, or if they do it will take quite some time.

This has been very long-awaited and it has always seemed odd to me that the UK has left the EU but a key part of our legislation, which impacts almost everyone daily to some extent, was still denominated in Euros. This will now be tidied up and the more practical changes may be useful too!