United Kingdom

The 2019 Amendment Regulations came into force on 10 January 2020 and introduced several changes to the Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017. These amendments were made to align UK law with the Fifth EU Money Laundering Directive (Directive 2018/843), particularly ahead of the UK’s EU withdrawal. Although the amendments do not directly revise the operational text of WTR articles, they extend the AML regime to new entities and processes that intersect with the wire transfer ecosystem.

New Obliged Entities & Extended Due Diligence

The regulations expanded the definition of obliged entities to include art market participants, letting agents involved in high-value rentals, and cryptoasset exchange and custodian wallet providers. These businesses are now required to conduct customer due diligence (CDD) and report suspicious activity. As many of these entities facilitate or receive electronic payments, they fall within the practical scope of wire transfer screening and information retention requirements.

Inclusion of Cryptoasset Providers

One of the most significant developments for WTR is the formal inclusion of cryptoasset businesses into the regulatory framework. Firms offering exchange or custody services for cryptoassets are now subject to AML and CDD obligations. This mirrors the logic of the FATF Travel Rule, which requires originator and beneficiary information for virtual asset transfers. These provisions anticipate future regulatory convergence between fiat and crypto transaction flows and enhance traceability within wire transfer-like environments involving digital assets.

Strengthened CDD & Beneficial Ownership Checks

The amendments require more detailed beneficial ownership verification, particularly when discrepancies exist between company registries and customer-provided data. PSPs, including banks and crypto-related businesses, must report inconsistencies and record the actions taken to resolve them. This provision supports the accuracy of payer and payee data in wire transfers, especially when cross-border and involving complex legal entities.

Enhanced Measures for High-Risk Countries

New rules mandate enhanced due diligence (EDD) for transactions where either party is established in a high-risk third country. This includes collecting additional information on ownership, business relationships, sources of funds, and the rationale for the transaction. These requirements directly align with the wire transfer obligation to collect meaningful payer and payee data for higher-risk transactions.

Bank Account Portal for Law Enforcement

A new Part 5A introduced the requirement for credit institutions and providers of safe custody services to respond to law enforcement requests through a central automated mechanism. The information includes account holders' names, dates of birth, addresses, and beneficial ownership information. Though not part of the WTR directly, this portal significantly enhances transparency and investigatory reach into funds transfer activity, especially for complex or layered transactions.

Conclusion: WTR Compliance Integration

The 2019 MLR amendments enhance the UK's AML regime in ways that support the aims of the Wire Transfer Regulation. By expanding the scope of regulated entities, formalising obligations for cryptoasset service providers, and strengthening due diligence and information-sharing mechanisms, the regulations build a more complete ecosystem for monitoring and tracing the origin and destination of electronic fund transfers. These reforms ensure that the UK remains aligned with international AML standards and FATF Travel Rule principles.