Upcoming Property changes to the UK Anti Money Laundering Regime - The Money Laundering and Terrorist Financing (Amendment) Regulations 2026

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (the “2026 Regulations”)

The 2026 Regulations were made on 30 June 2026. Most of the changes made to existing law by the 2026 Regulations came into effect on that date. The 2026 Regulations introduced a number of targeted reforms to the anti-money laundering regime in the UK (“AMLR”) to enhance its effectiveness.

Nature and scope of the changes

These AMLR changes focus on updating existing rules rather than replacing them, closing regulatory loopholes, and improving proportionality for firms. The aim is to improve risk-based approaches and reduce unnecessary over-compliance. 

Estate agents and lettings agents, as well as other types of business are subject to the AMLR. Changes to the AMLR effective from 14 May 2025 were significant for lettings agents in that such businesses then became classified as “relevant firms” under the Sanctions and Anti-Money Laundering Act 2018. That change meant that they became bound to carry out financial sanctions checks for all lettings regardless of the amount of the monthly rental payable under any lettings agreement. 

In contrast to the 2025 changes, the changes made by the 2026 Regulations only have a minor impact on estate agents and lettings agents. They will not face a completely new regime—but they will need to fine-tune their AML controls, especially as to :

• when and how they carry out due diligence. (The 2026 Regulations introduced a more refined approach to enhanced due diligence.)
• how they assess risk (The 2026 Regulations introduced a more genuinely risk-based approach.) 
• how they manage client accounts
• record keeping, document retention

Agents are likely to need: 

• more detailed firm-wide risk assessments
• better documentation of source-of-funds and source-of-wealth decisions
• clearer audit trails showing how risk ratings were reached, 
• responding to information requests (from banks or other third parties)  
• evidence that staff training and escalation procedures are actually working in practice.

In short, there will be less “box-ticking”  under the 2026 Regulations and, instead, more emphasis on demonstrable risk management and more targeted compliance. It will however require more work operationally.

What this means for AMLR-related Simply Docs templates and documents

We have reviewed all of our AMLR-related property templates and other documents and made minor updates as necessary to documents relating to estate agents and lettings agents. Additional updated AMLR-related templates can be viewed at May Business Newsletter and May Corporate Newsletter.