Summary of changes to the AML and counter-terrorist financing policy—Spring/Summer 2021—law firms

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

  • Summary of changes to the AML and counter-terrorist financing policy—Spring/Summer 2021—law firms

Summary of changes to the AML and counter-terrorist financing policy—Spring/Summer 2021—law firms

This Practice Note summarises changes to our Precedent: AML and counter-terrorist financing policy—law firms made in Spring 2021. The Precedent has been updated to reflect:

  1. Brexit

  2. SRA Sectoral Risk Assessment 2021

  3. Legal Sector Affinity Group (LSAG) AML guidance 2021, and

  4. SRA AML Visits report

This Practice Note is intended to help law firms update their policy for these specific changes. It will not be updated for any future changes.

This Practice Note does not contain detailed information on new, updated or expanded drafting notes to the policy.

SectionSummary of changesReason for change
1 Introduction to the policySection 1.1 removed ‘by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, SI 2019/1511, and from 6 October 2020, the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020, SI 2020/911’.General improvements.
2 Scope and applicationNone.Not applicable.
3 Responsibility for AML and counter-terrorist financing complianceSection 3 title updated to remove ‘anti-money laundering’ and replace with ‘AML’.
New sections 3.2 to 3.4 (MLCO) and reformatted section 3.5 (Nominated officer).
Expanded and consolidated drafting notes.
New SRA focus on MLCO role—see SRA AML Visits and general improvements.
4 Failure to comply with this policyNone.Not applicable.
5 Accounts proceduresSection 5.1 added ‘details of’ and removed ‘office business and client’.
Section 5.2.1 removed ‘Finance’ and replaced with ‘Accounts’.
Section 5.2.2 removed ‘Finance team’ and replaced

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