The Legal Sector Affinity Group (LSAG) has today published new UK AML guidance for the legal sector. This replaces previous versions of the guidance and has been published in draft form, pending approval by the Treasury.
The guidance was produced by collaboration between all UK legal sector professional bodies and supervisors, including CILEx Regulation, through the LSAG forum.
It expands upon the previous AML guidance released after the implementation of the The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and incorporates subsequent amendments implemented via:
Vicky Purtill, MLRO at CILEx Regulation, said:
We hope that the new guidance is helpful in providing practical information for all members of the legal profession on the requirements of the regulations.
As a sector we continue to see increasing risks and challenges connected to criminal activity and we recognise the need to support our firms and members in these challenging economic and social times.
The guidance should also be taken to communicate UK legal sector supervisory expectations to those under AML supervision.
Key changes include:
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- Revised, contents section with embedded links to sections for ease of navigation
- Introduction of “Key AML Compliance Principles”
- Revised, updated and expanded AML Governance and Internal Controls sections
- Fully revised and expanded Risk Assessment section (firm-wide, client and matter)
- Expanded guidance on understanding and evidencing source of funds and source of wealth
- A new section on technology – expanding on the requirement for firms to consider and understand the purposes and basis on which they are using AML-related technology (along with its underlying functionality) in order to use it effectively to mitigate risk
- Updated Training section
- Fully revised and updated Legal Professional Privilege section with new LPP/SAR reporting decision-making template
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