Lawyers & Solicitors

Law firms must regularly conduct thorough assessments to identify and evaluate the risks of money laundering they may encounter. These assessments should be conducted at the practice-wide, client, and matter levels. Practice Wide Risk Assessments (PWRAs) are mandated by Regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). 

PWRAs should be comprehensive in their identification and evaluation of all money laundering and terrorist financing risks faced by the practice. The PWRA is a crucial component of the anti-money laundering (AML) controls implemented throughout the business and must address specific issues outlined in the Regulations. 

Client risk assessments should focus on identifying and evaluating ML/TF risks at the individual client level. Matter risk assessments should be conducted for each new matter involving a client, especially when risks are unique or non-repetitive. As a Compliance Officer for Legal Practice (COLP), it is imperative to adhere to the guidelines set forth in MLR 2017. The following documents must be completed, reviewed, and signed off on an annual basis.

• Customer Due Diligence (CDD) and screening for Sanctions/Proliferation financing/SDN list search, PEP/RCA/SIP & Adverse/Negative news. 
• Identification of the Source of Funds, Red Flags/Internal SAR/Escalation to NCA. 
• Policy Packs including AML policy, controls and procedures (PCP), Anti-Bribery & Corruption Policy, Data Protection Policy, Website & Social Media Policy and Computer Use Policy. 
• AML Training for staff, training material, certificates, and training log. 
• Practice-wide risk assessment (PWRA), Client and Matter Risk assessment. 
• By diligently following these guidelines and conducting thorough risk assessments, law firms can effectively mitigate the risks associated with money laundering and terrorist financing.