The UK's Money Laundering and Terrorist Financing (Miscellaneous Amendments) Regulations 2018 have been laid before Parliament and will, if passed, come into force on 10th January.

The aim of these new regulations is to amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Oversight of Professional Body Anti-Money Laundering and Counter Terrorist Financing Supervision Regulations 2017 and the Solicitors (Scotland) Act 1980.

Regulation 29 of the 2017 regulations forbids a financial institution to set up an anonymous account or an anonymous passbook for any new or existing customer. The new regulation 3 intends to adds to this: "or an anonymous safe-deposit box." The financial institution must apply 'customer due diligence' ('know your customer') measures to all anonymous safe-deposit boxes in existence on 10th January and, in any event, before such safe-deposit boxes are used in any way.

Regulation-to-be 4 deals with appeals against the decisions of the Financial Conduct Authority Her Majesty’s Revenue and Customs. Regulation 93(1) of the 2017 regulations allows a firm to appeal against a decision that the FCA takes in accordance with those regulations to the Upper Tribunal. The new regulation 4 is designed to make this more explicit by saying that the firm can appeal against an FCA decision to: make a direction; register an applicant; suspend or cancel a firm's registration; impose a penalty; publish a censuring statement; limit, cancel or suspend anything to do with payment services; or impose a prohibition.

Regulation-to-be 5 is entitled "Oversight of Professional Body Anti-Money-Laundering and Counter Terrorist Financing Supervision Regulations 2017." It is the FCA's job to oversee the AML efforts of these trade bodies. The regulations it seeks to amend say that the FCA "may disclose information it holds to a relevant authority," i.e. to some other arm of the Government. Regulation 5, if passed, will widen the number of people to whom the FCA can give the information it gleans. It will not only allow the FCA to divulge information to relevant authorities but also to law enforcement authorities (where different) or "with a view to the institution of, or otherwise for the purposes of, any criminal or other enforcement proceedings."

According to the new regulation 7, HM Treasury must, from time to time, carry out a review of the regulatory provision contained in these regulations and publish a report setting out the conclusions of the review. The first report must be published before 26th June 2022.