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
  • Approval of beneficial owners, officers and managers
  • Staff vetting—good practice

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.

From 10 January 2020, an application to the SRA for approval of any new beneficial owner, officer or manager (BOOM) of a relevant firm must also be accompanied by:

  1. sufficient information to enable the SRA to determine whether the person concerned has been convicted of a relevant offence, and

  2. such other information as the SRA may reasonably require

See further: Approval of beneficial owners, officers and managers below.

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, and approval of BOOMs 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 (as amended).

Screening requirements in the MLR 2017

If the MLR 2017 apply to your firm, you