You and the Money Laundering Regulations 2017

As you read this, we expect that HM Treasury will have approved new guidance for the legal sector; this will be the first time that we have had one piece of guidance to cover all legal professionals. This is seen as a key part of the review of the whole Anti-money laundering (AML) regime. The AML supervisors are aware that this guidance will need further development to ensure that it is fully accessible to all the differing professions.

Key areas

The new regulations now include:

• Requirements for firms to carry out a risk assessment and then demonstrate how identified risks are addressed
• Key roles and controls
• A new ‘Super’ regulator for professional bodies
• Continuation of requirements for training
• Customer due diligence and ongoing monitoring 

CILEx Regulation and unregulated firms

We will have increased responsibilities under these regulations in identifying and supervising firms that need to comply with the regulations. Our authorised firms are already supervised by us for AML compliance.

However, if your firm is unregulated but either:

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

then you need to be supervised for AML and we can assist with this. 

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.

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