meta_id 3202235

On November 17, 2025, the Joint Money Laundering Steering Group (JMLSG) published proposed amendments to Part I of its Guidance on anti-money laundering and counter-terrorism financing compliance. The amendments reflect changes introduced by The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, which have been laid before parliament and are awaiting formal enactment. The JMLSG identified five key areas requiring revision. Paragraph 2.9 introduces clarification regarding the term "unusually" in the context of customer due diligence assessments. Paragraph 5.2.4A adds an exception relating to bank insolvencies, addressing how financial institutions should handle anti-money laundering obligations during insolvency proceedings. Paragraphs 5.3.142 and Annex 5-V contain updates concerning Professional Custodian Arrangements (PCAs), reflecting regulatory changes to how such arrangements are classified and managed. Paragraphs 5.3.94A and 5.3.99 amend provisions on Arrangement of Beneficial Ownership (AoBo), clarifying obligations for financial institutions arranging transactions involving beneficial ownership structures. These amendments are significant for financial institutions, money service businesses, and other regulated entities subject to anti-money laundering requirements under UK law. The revisions ensure compliance frameworks align with forthcoming legislative changes and provide clarity on complex compliance obligations. The consultation period closes on June 29, 2026. Stakeholders should submit comments to Carol Smit at caroljsmit@jmlsg.org.uk. The JMLSG will review responses before finalising the amended guidance, which will take effect following ministerial approval and the formal enactment of the 2026 amendment regulations.