The draft SI proposes targeted amendments to the MLRs and related legislation to address concerns identified in the March 2024 consultation. The draft SI also clarifies that EDD is now required only for transactions that are “unusually complex or unusually large” relative to sector norms. Pooled Client AccountsResponding to restricted access concerns, the draft SI decouples pooled client accounts (PCAs) from the simplified due diligence framework. Provisions relating to cryptoasset businesses will align with the FSMA cryptoasset perimeter implementation. The draft SI and Policy Note are available here and here, respectively.