The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 will shortly be amended to take account of changes imposed by the EU’s 5th Money Laundering Directive. The statutory instrument was laid before Parliament on Friday 20 December, and is available to view on the UK Parliament's website. Please note that the amended regulations will come into force on 10 January 2020 and we expect firms to take rapid action to ensure compliance. The Society recognises the short lead-in time for businesses to implement new requirements, and will take a proportionate and risk-based approach to non-compliance after this date.
In order to support our membership through these changes, we have been working closely with other legal sector supervisors to agree and jointly publish a “Key Changes Document”, which will be issued on 10 January 2020 or very shortly thereafter. We will publicise this document on our website, via a direct email to MLROs, and via the usual social media channels – please look out for this.
The Key Changes Document is part of a wider refresh of the UK Legal Sector AML Guidance currently underway. This revised guidance is due for publication in the Spring, pending HM Treasury approval. Further communications on this wider piece of work will be issued in the New Year.