AML and counter-terrorist financing policy—law firms

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

  • AML and counter-terrorist financing policy—law firms
  • 1 Introduction to the policy
  • 2 Scope and application
  • 3 Responsibility for AML and counter-terrorist financing compliance
  • 4 Failure to comply with this policy
  • 5 Accounts procedures
  • 6 What are money laundering and terrorist financing and why are they important to me?
  • 7 Money laundering/terrorist financing red flags and warning signs
  • 8 Money laundering offences
  • 9 Terrorist financing offences
  • More...

AML and counter-terrorist financing policy—law firms

This document reflects draft Legal Sector Affinity Group (LSAG) AML Guidance, published on 20 January 2021. It awaits HM Treasury approval. Note that any content may be amended before the final version is published with the Treasury's approval.

    1. 1

      Introduction to the policy

      1. 1.1

        [Firm name] is required to put in place appropriate systems and controls to combat money laundering and terrorist financing under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692 (MLR 2017), as amended.

      1. 1.2

        For more details on the MLR 2017, see section 10.

    1. 2

      Scope and application

      1. 2.1

        This policy contains the procedures we have developed to comply with the MLR 2017, as amended.

      1. 2.2

        This policy applies to all [our offices,] employees, officers, consultants, contractors and to other workers including agency workers, casual workers[, volunteers][, interns] and home workers.

      1. 2.3

        All staff must be familiar with this policy and comply with its terms.

      1. 2.4

        This policy does not form part of any contract of employment and we may amend it at any time.

    1. 3

      Responsibility for AML and counter-terrorist financing compliance

      1. 3.1

        The firm itself is primarily responsible for compliance with the MLR 2017, including all systems and control requirements.

      1. 3.2

        [While the firm is primarily responsible for compliance with the MLR 2017, we have appointed a money-laundering compliance officer (MLCO) and a nominated officer, as shown in the

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