Goldman Sachs staff face new UK anti-money laundering rules

Goldman Sachs employees in London and across EMEA now have to adjust how they onboard clients, document pooled accounts and escalate compliance breaches after the UK’s latest anti-money laundering amendments took effect. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June and, for most provisions, came into force on 30 June.

The amended rules require additional customer due diligence for pooled accounts, including a check on the purpose of the pooled account and a fresh assessment of money-laundering and terrorist-financing risk. That lands directly on onboarding teams, private wealth staff, front-office bankers handling complex client structures and the compliance teams that sign off on higher-risk relationships.

For Goldman’s London and EMEA staff, the practical test is whether existing client files still explain who the pooled account serves, how the account will be used and why the risks are acceptable. Teams that handle cross-border clients will also need to revisit their screening of high-risk third countries, because the government has aligned that definition more closely with the Financial Action Task Force public lists. HM Treasury updated its advisory notice on high-risk third countries on 22 June.

The changes raise the risk of workflow errors if policies, training and escalation paths are not updated together. Compliance teams will need to make sure their internal guidance matches the new risk-based framework, while operations and transaction-services staff will need to capture the extra account-purpose checks in a way that can be reviewed later by control functions or auditors. Managers should be checking now that staff know where pooled-account cases sit in the approval chain and when a file has to be kicked back for more evidence.

The new rules require notice to the Financial Conduct Authority within 30 days for certain material breaches. That gives legal, compliance and control teams a tighter clock on internal escalation, especially where an issue could affect client documentation, ownership analysis or sanctions-related screening. The FCA money laundering and terrorist financing guidance page was last updated on 11 February.