You and the new money laundering guidance

September saw the first piece of Anti-money laundering (AML) guidance to cover all legal professionals. Whilst it is marked draft as it requires final HM Treasury approval, this is seen as a key part of the review of the whole AML regime and reflects how AML supervisors are working together.

CILEx Regulation and its authorised firms

Authorised firms will follow this guidance as part of their AML supervision by CILEx Regulation. Simply, for consumers this will mean they will wish to understand the details of any transaction, the source and use of any money connected to the transaction, and request documents to confirm your identity. However, the regulations may require them to seek further information as required.

CILEx Regulation and unregulated firms

CILEx Regulation will now be identifying unregulated firms that need to comply with the regulations.

So, 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. 

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 guidance 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.