Money Laundering Regulations 2017—group level policies, controls and procedures—law firms

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

  • Money Laundering Regulations 2017—group level policies, controls and procedures—law firms
  • Group-level policies under MLR 2017
  • Identifying relevant group members
  • Parent and subsidiary undertakings
  • Do the requirements apply to your own firm's parent undertaking?
  • Dealing with local law requirements
  • Subsidiary undertakings and branches in a third country
  • Sharing client due diligence information with other parts of a group
  • Managing and communicating your group-level policies, controls and procedures

Money Laundering Regulations 2017—group level policies, controls and procedures—law firms

This document reflects draft Legal Sector Affinity Group (LSAG) AML guidance, published on 20 January 2021. It awaits HM Treasury approval. Note that any content may be amended before the final version is published with the Treasury's approval.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLR 2017), as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 from 10 January 2020, require firms that are subject to the MLR 2017 and are also parent undertakings to ensure their policies, controls and procedures apply across all branches and subsidiary undertakings outside the UK.

This Practice Note explains the requirements of the MLR 2017, as amended, to apply your anti-money laundering (AML) and counter-terrorist financing (CTF) policies, controls and procedures at group level. It reflects the requirements of the MLR 2017, as amended, and should be read in conjunction with Practice Note: Money Laundering Regulations 2017—systems and controls requirements—law firms.

Group-level policies under MLR 2017

The MLR 2017 introduce the concept of group-level policies, controls and procedures.

If your firm is a parent undertaking, you must:

  1. ensure your AML/CTF policies, controls and procedures apply to all your subsidiaries and branches (wherever located in the world), which carry out any of the regulated activities that have brought the firm within

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