Introduction#
Since 30 June 2026 the UK travel-rule threshold in the Money Laundering Regulations 2017 has been £800. The approved JMLSG guidance, Part II, still states €1,000. JMLSG says the guidance is being updated.
How it got here#
9 June 2026. HM Treasury made S.I. 2026/621. Regulations 32 and 33 substitute £800 for “1,000 euros” in regulations 64C(4) and 64G(1)(b). The instrument converts other euro thresholds to sterling one-for-one, “except where that would risk misalignment with FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. standards”, in the words of its explanatory memorandum. A one-for-one £1,000 would be worth more than €1,000, and would catch fewer transfers than FATF's baseline of 1,000 in euros or dollars.
30 June 2026. The new threshold came into force, 21 days after the instrument was made.
24 August 2026. The JMLSG Part II offered for download was the June 2023 text, as updated in December 2025. Its travel-rule annex (Sector 22) states the threshold as €1,000 at paragraphs 13 and 45. It tells firms to convert transaction values into euros. The figure “£800” does not appear in it. JMLSG's current-guidance page says the guidance “is currently being updated to reflect amendments per The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621)”.
The two texts#
| Text | What it says | Status |
|---|---|---|
| S.I. 2026/621 (HM Treasury) | £800, in place of “1,000 euros” | Regulation in force since 30 June 2026 |
| JMLSG Part II, Sector 22 | €1,000; convert values into euros | Approved guidance; JMLSG says an update is in progress |
€1,000 and £800 are not the same sum. A firm applying one figure is applying a different test from a firm applying the other.
What comes next#
No date yet
- A revised JMLSG Part II stating the £800 threshold.
Open questions#
- When will JMLSG publish the revised Part II, and when will HM Treasury approve it?
- How will the revised paragraph 45 handle conversionThe tort of treating someone else's goods as your own. Yuen v Li (2026) held it does not extend to crypto., now that the regulation states sterling?
What this is not#
- It is not divergence for its own sake. The explanatory memorandum ties the £800 figure to FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. standards.
- It is not a new rule in the guidance. The guidance has not yet changed.
Reading#
Primary
- S.I. 2026/621, the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, legislation.gov.uk, made 9 June 2026
- JMLSG current guidance, Joint Money Laundering Steering Group
Ours