Money Laundering Regulations 2017—screening employees—law firms
Money Laundering Regulations 2017—screening employees—law firms

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

  • Money Laundering Regulations 2017—screening employees—law firms
  • Screening requirements in the MLR 2017
  • Staff vetting—good practice

Forthcoming changes: The UK has voted to leave the EU and this will take place on exit day as defined in section 20 of the European Union (Withdrawal) Act 2018. This has implications for law firms. This Practice Note is likely to be affected. It will be updated as and when relevant implementing legislation is published. For more on Brexit, see Practice Notes: Brexit—anti-money laundering and counter-terrorist financing—law firms and Preparing for Brexit—key considerations and action planning—law firms.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 require firms subject to the regulations to carry out screening of relevant employees where it is appropriate having regard to the size and nature of the firm's business.Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, reg 21(1)(b)

Even if the requirements of the MLR 2017 do not apply to your firm, appropriate vetting of staff is a key element in ensuring the integrity of your crime prevention systems and should not be overlooked.

This Practice Note sets out the requirements of the MLR 2017 in relation to screening of relevant employees together with best practice in relation to staff vetting for roles in anti-money laundering (AML) compliance, even if the MLR 2017 do not apply. This Practice Note reflects the requirements of the MLR 2017 which came into force on 26 June 2017.

Screening requirements in the MLR 2017

If the MLR 2017 apply to your firm, you must carry out screening of relevant employees where it is appropriate having regard to the size and