Money laundering

Keeping the profession free of money laundering is in everyone’s interest. It is a key way of disrupting serious crime - crime that funds everything from terrorists to people traffickers. It is not a victimless crime.

Money laundering is a priority risk for us. The credibility of law firms make them an obvious target for criminals. The overwhelming majority of solicitors want to do the right thing. Yet that alone is not enough. Weak processes or undertrained staff can leave the door open for criminals.

Money laundering information

Guidance and warnings

The fifth Anti-money Laundering Directive (PDF 38 pages, 895KB) was published on 10 January 2020.

The Legal Services Affinity Group (LSAG) is producing guidance on the regulations which we will publish here soon. In the interim, a summary guidance of changes to the regulations (PDF 5 pages, 197KB) has been produced to help firms comply with the new requirements.

LSAG has produced guidance (PDF 156 pages, 1.4MB) on complying with your anti-money-laundering obligations.

We have produced guidance that accompanies this.

We have developed a risk assessment for the legal sector.

We have issued warning notices on money laundering, reminding everyone in the profession of their obligations, including:

Suspicious Activity Reports

All solicitors need to understand what they need to do under the Proceeds of Crime Act 2002 and Terrorism Act 2000.

If you have a suspicion that your firm is being used to launder money, your Money Laundering Reporting Officer (MLRO) must submit a SAR to the National Crime Agency (NCA). It’s important that everyone understands their responsibilities and their firm’s processes.

The NCA have concerns about the number and quality of SARs being submitted by law firms, and have produced guidance to help you, including:

We have also published a Warning notice: Money laundering and terrorist financing - suspicious activity reports.

Good practice and legal sector reviews

We have also carried out a number of recent reviews into how firms are doing  including:

These documents add to previous, similar resources. Such as our 2016 report on money laundering in the profession (PDF 37 pages, 316KB).

Information on people within your firm

We need to hold information on those working in the profession that hold certain roles.

Definition of positions

This guidance is to assist firms when deciding who in their firm falls under the definitions of beneficial owner, manager and officer contained in The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR).

While we want to assist you in interpreting the Government regulations, you will of course need to satisfy yourself on the legal position. The obligation to identify who are your beneficial owners, officers and managers is on you as a firm. If having read this guidance you are still unsure, you should consider obtaining specialist advice on your position.

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Who to contact

If you want advice about the questions, you can contact our Professional Ethics Guidance helpline.

If you need help with the form, call our Contact Centre.