Crypto Law Profile

Money Laundering and Terrorist Financing (Amendment) Regulations 2019

UK statutory instrument that implemented Fifth Anti-Money Laundering Directive changes and brought cryptoasset exchange and custodian wallet providers into the 2017 MLRs, with FCA registration and AML/CTF supervision from Jan. 10, 2020.

United Kingdom Effective Regulation Jan 10, 2020

At a glance

Status In force; most provisions commenced on Jan. 10, 2020.
Crypto scope Covers cryptoasset exchange providers and custodian wallet providers.
Crypto supervisor The FCA maintains the register and supervises in-scope UK crypto businesses.
Legal structure The instrument amends S.I. 2017/692 and should be read with the consolidated text.

Overview

The Money Laundering and Terrorist Financing (Amendment) Regulations 2019, S.I. 2019/1511, are a United Kingdom statutory instrument made on December 19, 2019. Most provisions entered into force on January 10, 2020. The instrument amended the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, commonly called the Money Laundering Regulations or MLRs.

The regulations implemented changes associated with the EU Fifth Anti-Money Laundering Directive and, for crypto markets, brought defined cryptoasset exchange providers and custodian wallet providers into the UK AML and counter-terrorist financing framework. Their legal effect is therefore mainly found in the amended 2017 MLRs rather than in a standalone crypto rulebook.

Cryptoasset scope under the 2019 Regulations

The instrument inserted a statutory definition of “cryptoasset” and two categories of covered business. A cryptoasset exchange provider includes a business exchanging cryptoassets for money, money for cryptoassets, or one cryptoasset for another. It also covers arranging those exchanges and operating automated machines that exchange cryptoassets and money. A custodian wallet provider is a business safeguarding customers’ cryptoassets or private cryptographic keys for holding, storing and transferring cryptoassets.

By adding those providers to the MLRs’ list of relevant persons, the instrument made the applicable risk-based AML controls part of their regulatory framework. These include business and customer risk assessment, proportionate policies and controls, customer due diligence, ongoing monitoring, recordkeeping, staff training and internal reporting procedures. The precise duties depend on the activity and the current consolidated MLR text.

FCA registration and supervision

The 2019 Regulations required the Financial Conduct Authority to maintain a register of cryptoasset exchange providers and custodian wallet providers. They also created a fit-and-proper test covering an applicant and relevant officers, managers and beneficial owners. The FCA received powers connected with registration, information gathering, skilled-person reports, suspension, cancellation and enforcement.

Current FCA guidance states that a business providing in-scope cryptoasset services by way of business in the United Kingdom must register before beginning those services. FCA registration under the MLRs is an AML supervisory status, not an endorsement of a firm or a general authorisation for every crypto activity.

Wider anti-money laundering changes

S.I. 2019/1511 was broader than crypto. It also extended the regulated sector to certain letting agents and art-market participants, broadened the tax-adviser definition, strengthened customer due diligence and beneficial-ownership checks, and introduced discrepancy reporting involving company ownership registers. Other provisions supported information exchange between financial intelligence units and expanded supervisory and enforcement arrangements.

A central bank-account and safe-deposit-box information mechanism was also added. That mechanism was designed to let specified authorities obtain account information for defined law-enforcement, intelligence and supervisory purposes. These non-crypto measures explain why the instrument should be classified as an AML/CFT regulation with crypto-specific licensing, registration and custody implications.

Commencement, review and current position

Most provisions commenced on January 10, 2020. The anonymous prepaid-card amendment commenced on July 10, 2020, while the bank-account portal and its related enforcement provision commenced on September 10, 2020. HM Treasury published a post-implementation review of the MLR framework on June 22, 2022.

As of June 19, 2026, the 2019 instrument is in force and its crypto changes remain embedded in the MLR framework. The 2017 MLRs have since been amended, so readers should use the current consolidated text. S.I. 2026/621 is scheduled to introduce further changes from June 30, 2026, with additional crypto-specific phases in 2027. The FCA also expects the wider UK financial-services regime for cryptoassets to begin on October 25, 2027.

Why the regulation matters for UK crypto law

The 2019 Regulations established the UK’s AML registration gateway for the defined exchange and custody activities. They did not create a comprehensive conduct, prudential or market-abuse regime for all cryptoassets. Their durable significance is narrower: specified crypto intermediaries became supervised entities within the UK’s financial-crime framework, with the FCA acting as registration and AML/CTF supervisor.

Key provisions

Crypto businesses added to the regulated sector

Adds cryptoasset exchange providers and custodian wallet providers to the businesses treated as relevant persons under the 2017 MLRs.

AML/CFT Jan 10, 2020 Source

Cryptoasset activity definitions

Covers fiat-to-crypto and crypto-to-crypto exchange, arranging exchange, crypto ATMs, and custodial safeguarding of cryptoassets or customers’ private keys.

Regulatory perimeter Jan 10, 2020 Source

FCA registration and fit-and-proper test

Requires the FCA to maintain the crypto register and applies a fit-and-proper test to applicants, officers, managers and beneficial owners.

Registration Jan 10, 2020 Source

Risk controls and customer due diligence

By bringing crypto businesses into the MLRs, applies risk-based controls, customer due diligence, monitoring, recordkeeping and internal reporting procedures where relevant.

Due diligence Jan 10, 2020 Source

FCA reporting and enforcement powers

Adds FCA information-gathering, reporting, skilled-person and enforcement powers for cryptoasset exchange and custodian wallet providers.

Supervision Jan 10, 2020 Source

Broader regulated-sector expansion

Also expands coverage to certain letting agents and art-market participants, broadens tax-adviser scope, and strengthens beneficial-ownership checks.

Sector scope Jan 10, 2020 Source

Bank account information mechanism

Creates a central mechanism for specified authorities to obtain information on bank and safe-deposit-box accounts, phased in from September 2020.

Information access Sep 10, 2020 Source

Timeline

  1. Regulations made

    HM Treasury made S.I. 2019/1511 under statutory powers covering money laundering, terrorist financing and related legislation.

    Enacted Source
  2. Laid before Parliament

    The instrument was laid before Parliament and published with an explanatory memorandum.

    Enacted Source
  3. Main provisions entered into force

    Most provisions, including the cryptoasset perimeter and FCA registration framework, entered into force.

    In force Source
  4. Prepaid-card provision commenced

    The anonymous prepaid-card customer due diligence amendment entered into force.

    In force Source
  5. Bank account portal provisions commenced

    The bank account portal provisions and related enforcement requirement entered into force.

    In force Source
  6. Post-implementation review published

    HM Treasury published the first post-implementation review covering the MLR framework and 5MLD changes.

    Enacted Source

Who it affects

Actors

Financial Conduct Authority, HM Treasury

Asset classes

Cryptoassets

Official sources

Editorial note

This profile covers S.I. 2019/1511 as an amending instrument. Its operative changes sit in the 2017 MLRs, which have been amended further. S.I. 2026/621 was made on June 9, 2026; most provisions commence June 30, 2026, with additional crypto-specific phases in 2027.