Money Laundering Regulations 2017—identifying and assessing firm-wide risks—law firms
Money Laundering Regulations 2017—identifying and assessing firm-wide risks—law firms

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

  • Money Laundering Regulations 2017—identifying and assessing firm-wide risks—law firms
  • Do you have to conduct a risk assessment?
  • Risk assessment and the risk-based approach
  • The risk assessment pyramid
  • What are appropriate steps?
  • Statutory categories of risk
  • Sources of information—external
  • Sources of information—internal
  • Record keeping
  • Who is responsible for the risk assessment?
  • more

This Practice Note explains the regulatory requirement to identify and assess firm-wide risks as set out in 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.

There is no right or wrong way to conduct a risk assessment; just ensure you are thorough. Look at what you do, and what you do not do.

But no matter how thorough your risk assessment or how appropriate your controls, some criminals may still succeed in exploiting your practice for criminal purposes. A comprehensive practice-wide risk assessment combined with appropriate risk-based judgements on individual clients and retainers will enable you to justify your decisions and actions to law enforcement agencies, the courts and your supervisory authority.

Do you have to conduct a risk assessment?

If the MLR 2017 apply to your firm, you must take appropriate steps to identify and assess your firm's money laundering and terrorist financing risks. For a sample risk assessment, see Precedent: Money laundering and terrorist financing firm-wide risk assessment—law firms.

For guidance on whether the MLR 2017 apply to your firm, see Practice Note: Money Laundering Regulations 2017—scope and application—law firms and Scope and application of the MLR 2017 for law firms—flowchart.

Risk assessment and the risk-based approach

You should not confuse

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