When it comes to anti-money laundering regulations, UK law firms face a complex web of responsibilities. From client due diligence to ongoing monitoring, the demands on legal practices continue to grow. But here's the good news: with the right approach and tools, you can turn these challenges into opportunities to strengthen your practice and build client trust.

Let's explore how your firm can stay ahead of AML requirements while maintaining efficient operations.

What are anti-money laundering regulations?

Money laundering and terrorist financing pose significant threats to the UK's financial system. The UK's anti-money laundering framework centres on two key pieces of legislation that every law firm must understand and follow.

At the heart of these regulations is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). These regulations outline specific obligations for law firms, requiring them to implement robust customer due diligence measures and maintain ongoing monitoring of business relationships. Working alongside this is the Proceeds of Crime Act 2002 (POCA), which establishes criminal offences related to money laundering and mandates that legal professionals report suspicious transactions to the National Crime Agency.

The Financial Action Task Force (FATF) regularly reviews and updates international standards, which often lead to new obligations being incorporated into UK law, making it essential for firms to stay current with evolving requirements.

Law firms are particularly vulnerable to being exploited for money laundering and terrorist financing risks due to their involvement in high-value transactions and their role in company formation and property deals. Criminals often attempt to use legal services to legitimise illegal funds, making it crucial for firms to maintain vigilance and implement adequate measures to prevent money laundering.

Key obligations for law firms under AML regulations

Understanding and complying with these regulations isn't optional—it's a fundamental requirement for operating in the regulated sector. Firms must establish internal controls, conduct regular risk assessments, and ensure their relevant employees are properly trained to identify and address money laundering risks.

Let's examine the key requirements that form the foundation of effective AML compliance for law firms.

Client due diligence (CDD)

Client due diligence lies at the heart of anti-money laundering regulations. Law firms must verify client identities through reliable documents such as passports and utility bills, or through modern digital ID verification tools. This ensures you know exactly who you're working with.

Beyond individual identification, firms must dig deeper when dealing with businesses or trusts. This requires gathering and verifying details about beneficial owners—those who ultimately control or benefit from the entity. Understanding these ownership structures is crucial for preventing money laundering through complex corporate arrangements.

Every transaction demands a careful assessment of its purpose and legitimacy. This includes identifying potential red flags that might indicate elevated risk and thoroughly investigating the source of funds. Modern automated tools can help flag suspicious activities, such as unusual transaction patterns or amounts that don't align with a client's known profile.

Enhanced due diligence (EDD) and enhanced ongoing monitoring

When dealing with high-risk situations, standard due diligence isn't enough. Firms must apply enhanced scrutiny when working with clients from high-risk jurisdictions, politically exposed persons (PEPs), or those involved in complex financial arrangements. This means conducting more detailed investigations into their background and activities. It's vital that firms collect comprehensive information about higher-risk clients' source of funds and their source of wealth.

Risk assessments

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Law firms must conduct regular risk assessments to stay compliant with the Money Laundering Regulations 2017 (MLR 2017) and prevent financial crime. These assessments should cover the firm as a whole—examining services, clients, and delivery channels—while also evaluating individual matters. By identifying risks early, firms can apply the right level of due diligence. Higher-risk clients may require enhanced checks, while lower-risk cases can follow a standard process. 

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Without a documented risk assessment, firms risk regulatory penalties and cannot justify their approach. Embedding risk assessments into daily practice strengthens AML compliance and protects the firm from financial crime.

Ongoing monitoring

Anti-money laundering compliance doesn't stop after initial checks. Firms must regularly review client matters that fall within the scope of the MLR 2017. This includes updating risk profiles as circumstances change and maintaining vigilant oversight of client activities.

Record-keeping forms a crucial part of ongoing monitoring. Firms must maintain consistent and detailed records of all monitoring activities, not just to ensure compliance but also to facilitate future audits. This documentation helps identify trends of non-compliance and areas where procedures might need strengthening.

Reporting suspicious activity

When money laundering is suspected, firms have a legal obligation to file Suspicious Activity Reports (SARs) with the National Crime Agency (NCA). This requirement forms a crucial part of the UK's anti-money laundering framework.

To ensure effective reporting, firms need robust internal escalation procedures. These procedures should enable staff to promptly report potential risks through appropriate channels. Firms should thoroughly document every step of this process, creating a clear audit trail that demonstrates compliance to regulators.

The challenges law firms face in staying compliant

While understanding your AML obligations is crucial, putting them into practice comes with significant challenges. Law firms of all sizes face various hurdles in maintaining effective compliance, from keeping up with regulatory changes to managing complex client profiles. Here are the key challenges that firms must navigate and overcome.

Evolving regulations

The regulatory landscape shifts frequently, requiring law firms to constantly update their practices and procedures. Compliance teams must monitor updates from international bodies like the Financial Action Task Force (FATF) while simultaneously adapting to changes in domestic frameworks such as the Money Laundering Regulations 2017. 

High administrative burden

The sheer volume of compliance work can overwhelm even well-resourced firms. Customer due diligence and enhanced due diligence processes require meticulous attention to detail and significant time investment. From gathering initial documentation to conducting thorough risk assessments, these essential tasks can strain your team's capacity. Gathering and reviewing large volumes of source of funds evidence adds another layer of complexity to an already demanding process.

High-risk scenarios

Some client relationships inherently carry greater compliance challenges. When working with PEPs) or clients from high-risk jurisdictions, firms must implement enhanced measures that require additional resources and expertise. 

Data management

In today's digital age, managing client data effectively is both crucial and challenging. Firms must establish robust systems for organising and securing vast amounts of client information, while also ensuring it remains readily accessible for compliance purposes. 

Best practices for law firms to ensure AML compliance

By following these best practices and implementing technology like Legl, firms can streamline key AML process processes while ensuring compliance. 

Conduct regular risk assessments

Risk assessment forms the foundation of effective AML compliance. Regularly analysing risks at firm-wide and individual client levels ensures tailored compliance measures. Legl’s risk-based assessment tools enhance this process by allowing firms to configure KYC levels based on client risk profiles, automatically adjusting due diligence and facilitating efficient escalation when necessary.

Implement robust internal controls

Strong internal controls include clear policies, designated compliance officers, and defined escalation protocols. Legl supports internal controls by maintaining comprehensive audit trails of all compliance activities and decisions, ensuring transparency and simplifying audits or regulatory reviews.

Leverage technology for compliance

Technology transforms AML compliance by automating client onboarding, risk assessments, and documentation management. For example, Legl streamlines client onboarding through automated KYC processes, including identity verification and document collection. 

This significantly reduces onboarding time while ensuring thorough compliance. Its ongoing monitoring system continuously checks client profiles against PEP lists, sanctions databases, and adverse media, alerting firms to potential risks in real-time.

What’s more, Legl integrates open banking technology to validate clients' financial information directly from their bank accounts—reducing the risk of falsified documents while streamlining the verification process.

Provide ongoing training

Even the best compliance systems rely on well-trained staff to function effectively. Regular training ensures your team stays current with the latest AML regulations and can spot suspicious activity when it occurs. Schedule periodic refresher sessions to keep compliance knowledge fresh and help your team adapt to evolving regulatory requirements.

Final thoughts

Anti-money laundering compliance represents a critical responsibility for law firms, but it doesn't have to be overwhelming. Maintaining effective AML practices can seem like a significant challenge. However, forward-thinking firms are turning these challenges into opportunities by embracing modern solutions that streamline compliance processes while strengthening client relationships.

Ready to transform your firm's approach to AML compliance? Book a demo with Legl today and discover how our platform can help your firm streamline processes, reduce risk, and stay ahead of regulatory requirements.