Your compliance team is probably focused on the big regulatory headlines. But the real work in 2026 is in the details—and the firms that miss these three changes will pay for it later.
Change 1: Pooled Accounts Are Under the Microscope
The draft Money Laundering Regulations 2026 amendments don’t require full Customer Due Diligence on every underlying client in pooled structures. But regulators now expect you to know who is actually behind the money—and to prove it. This means documenting the purpose of each pooled account, assessing money laundering risk within those structures, and being able to obtain underlying client information on demand. Your current onboarding and documentation standards probably won’t survive this test.
What you need to do: Review your account-opening documentation, escalation playbooks, and record-keeping practices. If a regulator asked you to explain who is behind a pooled account, could you answer? If not, fix it now.
Change 2: Geographic Risk Triggers Are Shifting
The automatic Enhanced Due Diligence trigger for “high-risk third countries” is being narrowed to focus only on Financial Action Task Force “Call for Action” countries. On the surface, this looks like a compliance relief. It’s not. This is a legal trigger change, not permission to relax your geographic risk assessment. Your risk-based approach still applies in full. The difference is which specific countries automatically trigger Enhanced Due Diligence—and many firms are already assuming they can reduce monitoring on countries that fall outside the new, narrower definition.
What you need to do: Audit your transaction-monitoring rules now. Make sure you’re not conflating the legal trigger change with a broader permission to reduce geographic risk assessment. Your monitoring rules should distinguish between automatic Enhanced Due Diligence triggers and risk-based judgment.
Change 3: Sterling Thresholds Are Not Simple Currency Conversions
Euro-denominated thresholds in the Money Laundering Regulations are being converted to pounds sterling. But this isn’t a straight exchange rate conversion. Some thresholds have shifted materially—the occasional transaction threshold drops from 1,000 euros to 800 pounds. If your monitoring rules still reference the euro amounts, or if you’ve simply plugged in an exchange rate, your Customer Due Diligence triggers are wrong. These gaps show up during supervisory examinations.
What you need to do: Pull your transaction-monitoring configuration and Customer Due Diligence rules. Recalculate every threshold. Don’t assume like-for-like equivalence—the regulations have changed, not just the currency.
Explore our FCA authorisation support for firms entering the UK financial market.
| The Blind Spots Most Firms Miss
These three changes are administrative but material. They’re not headline-grabbing, so many compliance teams will miss them until they show up in a supervisory examination. Start now while you have time to get it right. |
Need Help Mapping These Changes?
Get in touch with info@lhiconsult.com or visit lhiconsult.com to discuss your 2026 compliance audit.
LHI Consulting | Financial services regulatory strategy since 1999
