United Kingdom

The Money Laundering & Terrorist Financing (Amendment) Regulations 2022
The 2022 amendment to the Money Laundering Regulations focuses primarily on updates to the registration deadlines for trusts and clarifications concerning the types of trusts that are exempt from registration. Although the regulations do not amend the technical elements of the Wire Transfer Regulation directly, they form part of the same legislative instrument and regulatory ecosystem. These changes indirectly support the broader WTR framework by enhancing the transparency and accessibility of beneficial ownership information.
Trust Registration & Transparency
The core update introduced by the 2022 amendments is the extension of deadlines related to the Trust Registration Service (TRS). The deadline for registering existing taxable trusts was postponed to 1 September 2022. The time period for registering newly taxable trusts was extended from 30 to 90 days. These amendments aim to give trust administrators more time to comply, but also ensure that beneficial ownership data is recorded accurately and promptly.
Relevance to WTR Compliance
Although trust registration itself is not a component of FATF Recommendation 16 on wire transfers, the accuracy of beneficial ownership information plays a vital role in financial crime prevention. Wire transfer systems often rely on beneficial ownership checks when conducting customer due diligence or enhanced due diligence for high-risk transactions. By tightening deadlines and broadening the scope of what constitutes a non-registrable trust, the regulations support a stronger AML framework which complements the obligations under WTR.
Expanded Trust Exemptions
The 2022 amendments expanded the list of trusts exempt from registration. New exemptions include trusts linked to specific insurance policies and trusts created solely to open accounts for minors or persons lacking mental capacity. These clarifications help regulated firms distinguish between registrable and exempt trusts during onboarding or transaction monitoring processes, which is critical when assessing risk in the context of wire transfers.
Indirect Influence on PSP Risk Assessments
Payment service providers assessing WTR compliance may use trust registration data as part of their customer verification or sanctions screening obligations. Delays in registration or reliance on outdated beneficial ownership records can lead to gaps in identifying the originator or beneficiary of a wire transfer. The extended deadlines and expanded exemptions in the 2022 regulations may impact how PSPs evaluate risk and verify data at the point of transaction.
Conclusion: WTR Compliance Integration
While the 2022 MLR amendments do not revise the operational mechanics of the UK’s Wire Transfer Regulation, they support WTR compliance indirectly through improved transparency in beneficial ownership and clearer regulatory expectations for trusts. This contributes to a more effective risk-based approach across the AML regime, ensuring that PSPs and financial institutions can better manage the integrity of funds transfers in the UK’s regulated financial system.