HM Revenue & Customs (HMRC) has published a substantially updated version of its Anti-Money Laundering Guidance for Supervised Businesses, reflecting changes to the Money Laundering Regulations (MLRs) that came into force on 30 June 2026.
The revised guidance brings together HMRC’s expectations across risk assessments, policies and controls, customer due diligence (CDD), enhanced due diligence (EDD), ongoing monitoring, and suspicious activity reporting.
For HMRC-supervised businesses, the update provides an opportunity to review whether existing anti-money laundering (AML) frameworks remain aligned with the amended requirements and are working effectively.
Key Changes to HMRC’s Guidance
A central theme of the updated guidance is the importance of a risk-based approach. HMRC makes clear that supervised businesses must assess the money laundering, terrorist financing, and proliferation financing risks to which they are exposed.
Crucially, the risk assessment should inform the firm’s wider policies, controls, and procedures (PCPs). This means firms should be able to demonstrate a clear connection between the risks they have identified and the controls they have implemented to manage those risks.
HMRC also places emphasis on implementation. Having comprehensive AML policies is not enough if those policies are not effectively applied and enforced across the business. Firms should therefore consider not only whether their documentation is up to date, but whether senior management, employees, and where relevant, agents understand and consistently apply the controls in practice.
CDD, EDD and Higher-Risk Customers
The revised manual includes updated guidance covering CDD, identification and verification, reliance, ongoing monitoring, simplified due diligence, EDD, source of funds and source of wealth, politically exposed persons (PEPs) and record keeping.
There is also specific guidance concerning Financial Action Task Force (FATF) Call for Action countries. Firms should consider whether their existing geographical risk assessments and higher-risk customer procedures remain consistent with the amended MLR framework and HMRC’s guidance.
More broadly, the guidance reinforces that due diligence should be proportionate to the risks presented by the customer, business relationship, or transaction. Firms should be able to explain why particular measures were applied and demonstrate how higher-risk relationships are subject to appropriate scrutiny and ongoing monitoring.
Sector-Specific Expectations
Alongside its general guidance, HMRC provides sector-specific guidance for businesses including Money Service Businesses, Trust or Company Service Providers, Bill Payment Service Providers and Telecommunications, Digital and IT Payment Service Providers.
Firms should review both the general requirements and the guidance applicable to their particular sector and business model.
This is particularly important where the nature of the firm’s products, customers, distribution arrangements, or geographical exposure creates specific financial crime risks.
Next Steps for Firms
HMRC’s revised guidance provides an important reference point for supervised businesses following the June 2026 amendments to the MLRs. The update reinforces that effective AML compliance depends on more than maintaining the appropriate policies and procedures.
HMRC-supervised businesses may wish to use the updated guidance as a benchmark for reviewing their existing AML framework. This should include the business-wide risk assessment and the extent to which identified risks are reflected in the firm’s PCPs.
If you have questions about how HMRC’s updated anti-money laundering guidance affects your business, please contact an API Compliance consultant using the form below.
