Money laundering

Why this risk matters

  • The legal market can be an attractive target for those wishing to launder the proceeds of crime. In some cases, criminals instruct legal professionals to hold or transfer money because of the perceived legitimacy this offers
  • Solicitors have numerous regulatory and legal obligations to be aware of including the Criminal Finances Act and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
  • Solicitors have a duty to uphold the rule of law and support the proper administration of justice. Failing to meet their anti-money laundering obligations puts this at risk.

Trends

  • The number of Suspicious Activity Reports (SARs) submitted by the legal sector has risen for the first time in seven years, but is still disproportionately low.
  • Reports to us relating to money laundering have increased over recent years, with around a third relating to residential conveyancing.
  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 are now in force. The new obligations cover a range of areas including:
    • client due diligence
    • policies, controls and procedures
    • a central register of beneficial ownership
    • politically exposed persons
    • registration of trust and company service providers
    • criminality testing.
     

Actions

Further information