Upcoming changes to The Money Laundering Regulations 2017
09 June 2026
This notice is for casinos to be aware that the provisional date for the majority of changes to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘MLRs’) (opens in new tab) will come into force on 30 June 2026 (subject to parliamentary approval).
The MLRs Statutory Instruments (SI) (opens in new tab) was debated (and approved) by the House of Lords on 18 May 2026. Assuming that this is approved by Parliament, this means that most of the measures will come into force on 30 June 2026 (subject to parliamentary approval).
The following changes are relevant to the casino sector:
High risk third countries
Amendment to Regulation 33 of the MLRs in respect of high risk third countries, mandating enhanced customer due diligence (ECDD) measures only where the relevant transactions or customer relationships involve a person established in the Financial Action Taskforce’s (FATF) ‘Call for Action’ country list (opens in new tab) and not FATF’s 'Increased Monitoring' list (opens in new tab).
This represents a more risk-based approach which will enable casinos to focus on the money laundering and/or terrorist financing threats faced specifically by the UK.
Casinos will continue to be required to apply ECDD measures based on geographic risk factors, as per Regulation 33(6)(c) of the MLRs. This regulation lists several sources which firms must take into account when assessing geographic risk, including both FATF lists and other FATF assessments.
It is important for casinos to note that both lists are updated three times a year on the final day of each FATF Plenary meeting, held every February, June and October. The dates of these meetings are published several months in advance in the events calendar on the FATF website (opens in new tab). The FATF lists of countries are updated and published in full and can be found via the High-risk and other monitored jurisdictions page on the FATF website (opens in new tab).
Further clarification on business relationships
Among other circumstances, the MLRs require casinos to carry out customer due diligence measures where a business relationship has been established. Further details are to be provided in the Commission’s casino guidance in due course on the establishment of a business relationship.
Unusually complex and unusually large transactions
Regulation 33(f) of the MLRs requires casinos to conduct ECDD measures where the transaction is complex or unusually large. This will be amended to ‘unusually’ complex transactions instead of all complex transactions. The requirement for ECDD measures on unusually large transactions will remain unchanged. However, casinos must still consider wider geographic, product and customer risk factors when carrying out customer risk assessments.
Currency thresholds
References to Euros in the MLRs will be changed to Sterling instead, for example, the €2000 threshold under Regulation 27 of the MLRs will change to £2000 instead.
The Commission expects casino operators to update their money laundering and terrorist financing risk assessment along with their policies, procedures and controls accordingly as a result of these upcoming changes.
The Commission will issue a further update if there are any changes to the date when the measures come into effect or any further changes or amendments have been made to the previous list of proposed changes.
The Commission’s casino guidance will also be updated accordingly after these changes come into effect.