On 15 June 2022 HM Treasury published the outcome to its consultation on amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). The changes to the MLRs will be implemented through the Money Laundering and Terrorist Financing (Amendment) (No.2) Regulations 2022 Statutory Instrument. A draft of the Statutory Instrument and explanatory memorandum have also been published. The amendments bring the MLRs in line with updated FATF standards and fill gaps in the current operation of the UK’s AML regime, most significantly in relation to cryptoassets.
The Treasury’s publication of amendments to the MLRs was followed on 24 June 2022 by publication of two post-implementation reviews (PIRs) of the MLRs and Oversight of Professional Body Anti-Money Laundering and Counter Terrorist Financing Supervision Regulations 2017 (OPBAS Regulations) and a forward-looking review of the UK’s anti-money laundering and countering the financing of terrorism regime, responding to its Call for Evidence. Overall, the review suggests that the UK’s AML regime is working effectively enough that no wholesale changes are needed; instead, the Treasury will take an incremental approach to improvements and remedying deficiencies using structures already in place.
In this note we explain the key amendments to the MLRs taken forward by the Treasury, and explore in more detail the MLRs PIR and forward-looking review conclusions which relate to the financial services sector.