Feedback on follow-on consultation: AML/CFT/CPF Handbook enhancements to complex structures (2026-03)

Summary

This is the JFSC's feedback paper on its follow-on consultation regarding enhancements to the AML/CFT/CPF Handbook's treatment of complex structures. It summarises the 13 responses received (mostly from trust company business), explains the changes made to draft Handbook sections 4.8 (CDD) and 7.8 (EDD) as a result, and confirms the implementation timetable.

• Two-tier approach retained: Complexity in a customer structure does not automatically mean higher risk; EDD applies only where complexity contributes to a high-risk assessment.
• Section 4.8 changes: Indicators of complexity are clarified as non-prescriptive and non-exhaustive; the minimum baseline for number of jurisdictions and types of legal persons/arrangements is raised from two to three; fragmented administration and unusual payment flows added as indicators; sector-specific legal form references removed.
• Section 7.8 changes: Paragraph 81 aligned with COP73 so EDD applies only where complexity drives a high-risk rating; the EDD measures list in paragraph 82 is confirmed non-exhaustive and not a checklist; no blanket Source of Wealth/Source of Funds requirement for controllers who do not contribute funds or have no economic interest.
• No new obligations: The JFSC states that, other than the single Code of Practice provision, the revisions are guidance only and do not create new obligations beyond existing standards.
• Existing customers: No immediate wholesale refresh of customer risk assessments or documentation is expected; changes should be addressed via periodic reviews and trigger events as part of business-as-usual monitoring.
• Implementation timetable: Feedback paper and revised consolidated Handbook (including sections 4.8 and 7.8) published 26 March 2026; the Handbook becomes effective on 31 May 2026, despite industry requests for a longer (three to six month) implementation period.

Firms are expected to update their policies and procedures to reflect the revised sections ahead of the 31 May 2026 go-live, while treating the guidance as clarifying existing risk-based obligations rather than imposing new ones.

Key obligations

• Firms should update policies and procedures to give effect to the revised sections 4.8 and 7.8 of the AML/CFT/CPF Handbook.
• Firms should address any resulting changes to existing customer risk assessments through periodic reviews or trigger events as part of business-as-usual monitoring, rather than an immediate wholesale refresh.

Applies to

trust company business/trust company service provider, bank, fund services business, other regulated financial services business (e.g. investment business, insurance, money service business, general insurance mediation business), other designated non-financial businesses and professions (e.g. lawyers, accountants, estate agents), supervised persons/reporting entities

Deadlines

• 26 March 2026: Publication of the feedback paper and revised consolidated AML/CFT/CPF Handbook, including the revised sections 4.8 and 7.8 on complex structures.
• 31 May 2026: Effective date (go-live) of the revised AML/CFT/CPF Handbook, including the amended sections 4.8 (CDD) and 7.8 (EDD) on complex structures.