Money Laundering Regulations 2017—staff training and awareness—law firms
Money Laundering Regulations 2017—staff training and awareness—law firms

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

  • Money Laundering Regulations 2017—staff training and awareness—law firms
  • Training requirements in the MLR 2017
  • Determining what measures are appropriate
  • Identifying relevant employees
  • Form of training
  • Frequency of training
  • Training—good practice
  • Promoting awareness

STOP PRESS: Draft Legal Sector Affinity Group (LSAG) AML guidance was published on 20 January 2021. It awaits approval by HM Treasury and any content may be amended before the final version is published with the Treasury's approval. This document reflects HM Treasury approved LSAG AML guidance published in 2018 and will be updated in due course.

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511 from 10 January 2020, include requirements relating to staff training and awareness, which are compulsory for firms caught by the Regulations (relevant persons).

Even if the requirements of the MLR 2017 do not apply to your firm, the Proceeds of Crime Act 2002 (POCA 2002) and the Terrorism Act 2000 (TA 2000) still apply to your partners and staff as private individuals, eg if they become involved in something they know or suspect is connected to money laundering, they have a legal obligation to report it. The SRA requires you to ensure your managers and staff are competent to carry out their role, and keep their professional knowledge and skills, as well as understanding of their legal, ethical and regulatory obligations, up to date. As a result, whether or not your firm is subject to the MLR

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