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Changes to AML Regulations

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New changes to the Money Laundering Regulations 2017 took effect on 18 November, following the introduction of the Economic Crime and Corporate Transparency Act 2023. These amendments specifically impact how firms interact with the Register of Overseas Entities.

Two key updates have been implemented:

First, Regulation 28 has been clarified to confirm that the Register of Overseas Entities cannot be the sole source used to verify beneficial ownership. This change ensures the register is treated with the same level of scrutiny as the Companies House register, requiring firms to conduct further verification.

Second, Regulation 30A now includes the Register of Overseas Entities within the discrepancy reporting regime. This means firms are now required to report any material inconsistencies they find between the information on the register and the information gathered during their own due diligence.

Looking ahead, the Solicitors Regulation Authority has indicated that further amendments based on HM Treasury’s recent consultation are expected in early 2026.

In light of these developments, firms should review their current AML compliance frameworks. It is advisable to consider any appropriate updates to AML policies or the Firm-Wide Risk Assessment to ensure these new requirements regarding the Register of Overseas Entities and discrepancy reporting are accurately reflected in daily operations.

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