Improving the effectiveness of the Money Laundering Regulations - ACCA comments - TECH-CDR-2129

Aug 29, 2026

Uploaded by Jacob

ACCA provides comments on HM Treasury’s public consultation aimed at improving the effectiveness of the UK Money Laundering Regulations (MLRs). The response supports an effective AML supervisory regime and proposes changes to keep the legislation proportionate, including updating currency thresholds to pound sterling and strengthening information sharing. Key concerns include wording changes in regulation 33(1)(f), non-mandatory requirements for high-risk third countries, and alignment of identity verification requirements to avoid uncertainty, confusion, and increased costs. ACCA also notes continued uncertainty due to delayed publication of consultation outcomes.

LanguageEnglish

CategoryExam

FormatPDF

Pages19

Reading Time48 min

AccessFree to download

General comments

Customer due diligence proportionate and effective

Due diligence triggers for non-financial firms

Source of funds checks

Verifying persons acting on behalf of a customer

Improving the effectiveness of the Money Laundering Regulations A consultation issued for public consultation by HM Treasury (HMT) Comments from ACCA 7 June 2024 Ref: TECH-CDR-2129 We are ACCA (the Association of Chartered Certified Accountants), a globally recognised professional accountancy body providing qualifications and advancing standards in accountancy worldwide. Founded in 1904 to widen access to the accountancy profession, we’ve long championed inclusion and today proudly support a diverse community of over 252,500 members and 526,000 future members in 180 countries. Our forward-looking qualifications, continuous learning and insights are respected and valued by employers in every sector. They equip individuals with the business and finance expertise and ethical judgment to create, protect, and report the sustainable value delivered by organisations and economies. Guided by our purpose and values, our vision is to develop the accountancy profession the world needs. Partnering with policymakers, standard setters, the donor community, educatorsand other accountancy bodies, we’re strengthening and building a profession that drives a sustainable future for all. [Find out more at:](Find out more at: www.accaglobal.com)[ ](Find out more at: www.accaglobal.com)[www.accaglobal.com](Find out more at: www.accaglobal.com) Further information about ACCA’s comments on the matters discussed here can be requested from: Stefan Pegram Director – Practice Regulation [stefan.pegram@accaglobal.com](stefan.pegram@accaglobal.com) Wesley Walsh Head of AML [wesley.walsh@accaglobal.com](wesley.walsh@accaglobal.com) GENERAL COMMENTS ACCA is a Professional Body Supervisor (PBS) for anti-money laundering (AML) in the UK. We welcome the opportunity to provide views on the government’s proposals to improve the effectiveness of the Money Laundering Regulations (MLRs) . Our response to this consultation has been informed by input obtained from our supervised population and discussions with other accountancy PBSs. ACCA fully supports the development of an effective UK AML supervisory regime that provides confidence in the UK as a safe, transparent and compliant jurisdiction to conduct business in. We believe that a robust and effective framework to tackle economic crime will help improve and facilitate further commercial activity for businesses in the UK. We are generally supportive of the proposed changes to the MLRs to ensure that the legislation remains proportionate and effective. For example, we welcome the proposals to update the MLRs so that financial thresholds are in pound sterling rather than euros, and the suggested proposals to strengthen information sharing. However, we have identified some areas of concern and these are highlighted in our responses to the questions raised where appropriate. In particular, we have concerns about the proposal to change the wording in regulation 33(1)(f) from ‘complex’ to ‘unusually complex’ as we believe this will create uncertainty and inconsistency of application. We also have concerns about the implications of making the list of requirements for high-risk third countries non-mandatory, and the potential consequence that firms may not conduct appropriate checks because there is no mandatory requirement. We also note that changes to UK company law relating to identity verification are being introduced. ACCA supports the strengthening of the integrity of the Companies House register and the benefits this will bring. However, we suggest that alignment of the identity requirements across all the regulations is essential, as differences in the statutory requirements could result in confusion and additional cost and reduce the effectiveness of regulatory aims. Finally, we are disappointed that HMT is yet to publish the outcome to the public consultation on the Reform of the Anti-Money Laundering and Counter Terrorism Financing Supervisory Regime, despite commit

FAQs

What is ACCA’s overall position on HM Treasury’s proposed changes to the MLRs?

ACCA is generally supportive of changes intended to keep the MLRs proportionate and effective, including updating currency thresholds to pound sterling and strengthening information sharing.

Why does ACCA raise concerns about proposed wording changes in regulation 33(1)(f)?

ACCA believes changing ‘complex’ to ‘unusually complex’ would create uncertainty and inconsistency in how the rule is applied.

What concerns does ACCA have regarding non-mandatory high-risk third-country requirements?

ACCA is concerned that making the requirements non-mandatory may lead firms to conduct inadequate checks because there would be no mandatory obligation.

Aug 29, 2026

Uploaded by Jacob