Executive Summary on the Transposition of 5 MLD into UK Law

Updated: Aug 5, 2019

On 15 April 2019, HM Treasury published a consultation paper on the transposition of 5 MLD into UK law. This will involve amendment to MLR 2017 or perhaps a completely new set of regulations.

It is a lengthy document (84pp) and poses 106 questions.

This Insight will not summarise the paper but seek to indicate the direction of travel in summary form that the Government appears to be taking in a few selected areas

Letting Agents

Should the EUR10,000/month limit be lowered? Should private landlords be included? Should CDD be carried out on both the landlord and tenant? Should BOs, officers and managers be subject to approval under Reg26?

HMRC to be the supervisor.


To include exchange, security and utility tokens. The UK may add provisions to those in 5MLD to include crypto-to-crypto exchanges, initial coin offerings (ICOs), peer-to-peer exchanges and crypto ATMs. Further consultation on the regulatory perimeter in relation in security and utility tokens.

FCA to be the supervisor.

Art Intermediaries

Closely parallels treatment of high value traders except it covers all payments over the threshold not just those made in cash. UK to define ‘works of art’.