Money Laundering Regulations 2017—independent money laundering compliance audit plan—law firms
Money Laundering Regulations 2017—independent money laundering compliance audit plan—law firms

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

  • Money Laundering Regulations 2017—independent money laundering compliance audit plan—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

      Preparing for the audit

      This section sets out a checklist of issues to be addressed pre-audit.

      ActionCompletedComments and action points
      Obtain copy of firm-wide anti-money laundering (AML) and counter-terrorist financing (CTF) risk assessment[Insert date completed][Insert any comments or action points]
      Obtain copies of all AML and CTF compliance policies and procedures[Insert date completed][Insert any comments or action points]
      Determine how many files are to be reviewed and which practice areas they should come from[Insert date completed][Insert any comments or action points]
      Identify client/matter files for review[Insert date completed][Insert any comments or action points]
      Arrange access to all relevant internal systems, files and records, eg:
      —practice management system
      —document management system
      —client matter inception
      —client due diligence (CDD) records
      —breaches registers
      [Insert date completed][Insert any comments or action points]
      Arrange access to any externally-provided systems used in connection with AML, eg external verification systems or training courses[Insert date completed][Insert any comments or action points]
      Obtain copies of AML and CTF training records[Insert date completed][Insert any comments or action points]
      Identify partners and staff to be interviewed[Insert date completed][Insert any comments or action points]
      Confirm availability of relevant partners and staff during audit window[Insert date

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