Money Laundering Regulations 2017—enhanced due diligence—law firms
Money Laundering Regulations 2017—enhanced due diligence—law firms

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • Money Laundering Regulations 2017—enhanced due diligence—law firms
  • EDD triggers
  • Matters identified by firm-wide risk assessment
  • High-risk third countries
  • Politically exposed persons (PEPs)
  • Client provided false or stolen identification documentation or information
  • Complex or unusual transactions
  • Other high risk matters
  • Product/transaction favours anonymity
  • Non-face-to-face clients
  • more

This Practice Note explains your obligations around enhanced due diligence (EDD) and what it means for you in practice. It reflects the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, which came into force on 26 June 2017, as amended from 10 January 2020 by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511.

EDD triggers

You must apply EDD measures and enhanced ongoing monitoring:

  1. in any case identified as presenting a high risk of money laundering or terrorist financing in your firm-wide risk assessment or by your supervisory authority

  2. in any business relationship with a person established in a high-risk third country or in relation to any relevant transaction where either of the parties to the transaction is established in a high-risk third country—see High-risk third countries below

  3. where you have determined that the client/potential client is a politically exposed person (PEP), or a family member or known close associate of a PEP

  4. where you discover that a client has provided false or stolen identification documentation or information for client due diligence (CDD) purposes, and you propose to continue to deal with that client

  5. in any case where:

    1. a transaction is complex or unusually large

    2. there is an unusual pattern of transactions, or

    3. the transaction or transactions