The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, known as SI 2026/621, were made on 9 June 2026 and came into force 21 days later, around 30 June 2026. It is easy to conflate this instrument with the UK's much larger, separate move to give the FCA sole AML/CTF supervision of legal, accountancy and trust and company service providers. They are different reforms on different timelines, and firms that mix them up risk building the wrong compliance response.
This article sets out what SI 2026/621 itself changes, including a lower currency threshold for occasional transactions and new obligations on FCA-supervised firms to flag material changes to information they have already provided, and what that means for customer due diligence and monitoring workflows.
What SI 2026/621 actually amends
SI 2026/621 makes targeted amendments to the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Among the changes, regulation 27 on customer due diligence is amended so that the occasional-transaction threshold that triggers CDD falls from 1,000 euros to £800, a meaningfully lower bar that brings more occasional transactions into scope for identity verification.
The instrument also inserts a new ongoing obligation: where an authorised person supervised by the FCA has given the FCA information under the Regulations, and that information later changes materially or turns out to be inaccurate, the firm must notify the FCA within 30 days of the change or the discovery. That is a standing reporting duty, not a one-off filing, and it needs an internal trigger and owner, not just a note in a policy document.
Why this is not the FCA supervisory reform, and why that matters
Separately, HM Treasury has been progressing a much larger reform: transferring AML/CTF supervision of legal, accountancy and trust and company service providers from the SRA, other professional bodies and HMRC to the FCA, creating what has been described as a single professional services supervisor. Treasury issued its response to the consultation on the FCA's powers on 21 July 2026, but the transition depends on primary legislation that had not been scheduled as of that response, and the current supervisory framework is expected to remain in place through 2026 and into 2027.
The Institute of Chartered Accountants in England and Wales was explicit in April 2026 that 'the changes do not pertain to supervisory reform' when discussing the incoming SI. Treating SI 2026/621 and the supervisory transfer as the same event risks either under-preparing for the threshold change that is already in force, or over-preparing for a supervisory handover that is still some way off.
Operational impact on due diligence and monitoring
The lower occasional-transaction threshold widens the population of transactions that need identity verification before they proceed, which has a direct knock-on effect for firms relying on manual or ad hoc CDD for lower-value, one-off customers. Automating identification and screening at the point of an occasional transaction, rather than only for ongoing relationships, becomes more important as the threshold falls.
The 30-day change and inaccuracy notification duty is a governance point as much as a technical one. It requires firms to know what information they have previously given the FCA, track material changes against it, and have a clear internal escalation path so the 30-day clock does not start running before compliance even knows about the change.
Practical steps for FCA-supervised firms
Firms should first confirm whether their occasional-transaction CDD triggers are still calibrated to a euro-linked or informal sterling equivalent, and update thresholds to the new £800 figure where relevant. Second, they should assign clear ownership for the new 30-day notification duty, including a log of what information has been supplied to the FCA and when, so a later change is easy to spot.
Firms should also keep the supervisory reform on a separate watch item. Its primary legislation had not been scheduled as of Treasury's July 2026 response, so specific FCA supervisory expectations for newly transferred sectors are not yet confirmed, and firms should avoid building processes around assumptions that have not yet been legislated.
