MLR 2017 vs BSA
MLR 2017
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
BSA
Bank Secrecy Act 1970 (codified at 31 U.S.C. § 5311 et seq.), with major amendments by the USA PATRIOT Act 2001 and the Anti-Money Laundering Act 2020.
MLR 2017
United Kingdom — applies to relevant persons including financial institutions and a wide range of designated non-financial businesses.
BSA
United States — applies to financial institutions as defined under 31 CFR Chapter X, including banks, MSBs, casinos, and certain non-bank entities.
MLR 2017
FCA, HMRC, and 22 Professional Body Supervisors (Law Society, ICAEW, etc.) depending on sector.
BSA
FinCEN administers the BSA. Functional regulators (OCC, FRB, FDIC, NCUA, SEC, CFTC) examine for compliance.
MLR 2017
Financial institutions, accountants, auditors, tax advisers, legal professionals, TCSPs, estate agents, letting agents, casinos, dealers in high-value goods, art-market participants, and crypto-asset businesses.
BSA
Banks, money services businesses, broker-dealers, mutual funds, futures commission merchants, casinos, and certain non-bank residential mortgage lenders. Coverage is narrower for non-financial sectors than the UK MLRs.
MLR 2017
Risk-based CDD with EDD for high-risk relationships and PEPs. Source of funds and beneficial ownership identification required.
BSA
CIP (Customer Identification Program) plus the CDD Final Rule requiring beneficial ownership identification for legal entity customers.
MLR 2017
Suspicious Activity Reports filed with the National Crime Agency.
BSA
Suspicious Activity Reports and Currency Transaction Reports filed with FinCEN.
MLR 2017
Unlimited fines and up to two years' imprisonment for breaches; FCA can impose civil penalties without cap.
BSA
Civil penalties up to USD 1 million per violation or 1% of assets (whichever is greater), plus criminal penalties up to 20 years' imprisonment.
MLR 2017
Cash transactions of EUR 10,000 or more in dealers in high-value goods trigger AML obligations.
BSA
Currency Transaction Reports required for cash transactions exceeding USD 10,000.
Practical implication for cross-border firms
UK non-financial institutions with US-resident principals or US-incorporated counterparties may be in scope of both regimes. The biggest divergence is in non-financial coverage: the MLRs apply to law firms, accountants, art-market participants, estate agents, and TCSPs; the BSA's reach over those sectors is narrower. See related comparisons: OFAC vs OFSI and EU vs UK Sanctions.
FAQ
Questions firms ask
Common questions about the UK MLRs and US BSA.
Still have a question?
hello@firmscreen.io
The UK Money Laundering Regulations 2017 implement the EU 4th AML Directive (and 5th AMLD via amendment) and apply to a broad set of regulated sectors including legal, accountancy, real estate, and high-value dealers. The US Bank Secrecy Act primarily targets banks and financial institutions; coverage of non-financial sectors is narrower and largely added through the AMLA 2020.
The UK MLRs cast a wider net over non-financial businesses (legal, accounting, art, real estate, TCSPs) with active supervision by sector-specific Professional Body Supervisors. The BSA traditionally focused on banks; non-bank coverage is expanding under AMLA 2020 but remains narrower.
Both regimes require risk-based CDD, beneficial ownership identification, and enhanced due diligence for higher-risk customers. The detailed thresholds and triggers differ — for example, the UK uses a EUR 10,000 cash threshold for high-value dealers, while the US uses a USD 10,000 CTR threshold.
Yes. FirmScreen's name screening covers OFAC, OFSI, EU, and UN sanctions lists, supporting compliance under both the MLRs (UK) and the BSA (US).
One tool, both regimes
FirmScreen supports MLR 2017 and BSA-aligned screening with OFAC, OFSI, EU, and UN list coverage in a single check.
Book a demo