HM Treasury review of the Money Laundering Regulations 2017

The consultations

HM Treasury is holding two consultations as part of its twin-track approach to reviewing the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs):

Amendments to MLRs 2017 statutory instrument

The statutory instrument consultation is a targeted set of changes seeking views on:

  • the implementation of changes to Financial Action Task Force (FATF) requirements to maintain the UK’s compliance with international AML standards on, for example:
    • the regulation of virtual assets
    • the requirement to carry out risk assessments on proliferation financing 
  • a series of small measures to address issues identified following the 2019 amendments to the MLRs

HM Treasury hopes that this will help to clarify the regulations and strengthen the supervision regime.

Review of the AML regulatory and supervisory regime

This call for evidence seeks to comply with the obligation in the MLRs and the economic crime plan to review the effectiveness and scope of the MLRs and Office for Professional Body Anti-money laundering Supervision (OPBAS) regulations by June 2022.

It’s a more extensive review of the MLRs that provides an opportunity to consider how to approach future reform in the absence of the requirement to follow new EU Directives.

The overarching aim is to seek views on how the MLRs could change to enhance effectiveness.

The call for evidence has been structured into three themes:

  • the overall effectiveness of the regime
  • whether key elements of the current MLRs are operating as intended
  • the structure of the supervisory regime, including the effectiveness and consistency of OPBAS's work to improve supervision by professional body supervisors 

Whilst FATF Standards and the risk-based approach will remain the foundation of the MLRs, this is an opportunity to step back and seek views on potentially transformative changes to support the UK’s overall economic crime objectives.

Next steps

Both consultations will close on 14 October 2021.

HM Treasury will be seeking the views of industry stakeholders including the Law Society through a series of targeted engagement sessions over summer and autumn.

These sessions will provide an opportunity for us to discuss the key areas of focus which are beginning to emerge and a selection of the questions posed within the publications, ensuring the profession and our members’ views are represented.

Get involved

We’ll draw on the expertise of our Money Laundering Taskforce and wider membership to respond to both consultations.

We’re keen to hear from you to inform our responses. To share your views, email Rick Kent, our anti-money laundering and economic crime manager.

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