Category: Compliance & AML · Reviewed by Matt Bartlett, Director · Founder · Last reviewed June 2026
The full title of MLR 2017 — the UK statutory instrument that incorporates both money laundering / terrorist financing duties and the EU Transfer of Funds (Wire Transfer) information requirements into a single regulatory framework.
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (commonly “MLR 2017”) combine two regulatory regimes: (a) the anti-money laundering / counter-terrorist financing framework derived from the EU 4th Money Laundering Directive (and subsequent amendments); and (b) the Transfer of Funds (Wire Transfer) information requirements which require payer / payee information to accompany electronic transfers above prescribed thresholds.
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (S.I. 2017/692), as amended. The Wire Transfer Regulation component implements what was Regulation (EU) 2015/847, retained in UK law. The Treasury and HMRC supervise compliance for some sectors (HMRC for money service businesses and accountants; FCA for credit and financial institutions including most insurance intermediaries in scope).
The Wire Transfer side is principally a payment-systems duty — but it interacts with insurance distribution where firms operate premium credit facilities or large cross-border refund flows. The AML side is the dominant operational duty for insurance intermediaries: risk assessments, CDD, EDD where required, training, MLRO appointment, record-keeping (typically five years from the end of the business relationship under regulation 40) and SAR submission.
Different supervisor bodies apply. For insurance distribution, the FCA is the supervisor. Trust and Company Service Providers are supervised by HMRC. Professional services may be supervised by their Designated Professional Body (e.g. the Solicitors Regulation Authority). The Wire Transfer threshold (€1,000 equivalent) applies for full payer / payee information; below this, simplified rules apply with subsequent traceability.
Apex’s risk-based AML procedures cover CDD on policyholders for life and pension business (which Apex does not currently transact) and the broader counter-financial-crime framework under SYSC 6.3 for general insurance. Wire Transfer requirements apply where the firm processes payments outside risk transfer arrangements.
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (S.I. 2017/692). UK retained Regulation (EU) 2015/847 on the information accompanying transfers of funds. HM Treasury supervisory framework.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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