Update: You and the new money laundering guidance

A lot of work has been carried out recently by the Anti-money laundering (AML) supervisors to implement the Money Laundering Regulations 2017. The regulations impact us all. David Pope reports.

March saw the AML guidance gain its final HM Treasury approval, and with the new oversight regulator Office for Professional Body Anti-money laundering Supervisors now set in legislation, focus turns to ensuring that the regulations are being complied with.

Consumers and AML

Consumers will continue to see firms wanting to understand the details of any transaction, the source and use of any money connected to the transaction, and requesting documents to confirm your identity. You should expect more enquiries than just, “Can I have a copy of your passport and a utility bill please”.

CILEx Regulation and its authorised firms

Authorised firms will be supervised by CILEx Regulation for compliance with the regulations.

CILEx Regulation and unregulated firms

If your firm is unregulated but either:

  • sets up, operates or manages trusts, companies, foundations or similar structures; or
  • manages client money,

then you may need to be supervised for AML. 

However, all unregulated firms should check whether they need to be supervised.

What to do

  • Check whether the AML regulations apply to your work as an independent legal professional in an unregulated firm.
  • Check whether you are registered for AML supervision with another supervisor, say HMRC.

The legal sector guidance can be found here. Guidance from the government on registering can be found here.

If you should be and are currently not being supervised, then let us know at: info@cilexregulation.org.uk so that we can see if you can be included within the support and guidance that we provide.


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