New requirement will help Society comply with regulations

The Law Society of Scotland is introducing an online AML certificate in October as part of its ongoing work to strengthen anti-money laundering procedures within the legal sector and meet the requirements of the 2017 Money Laundering Regulations.

The AML certificate is a questionnaire designed to collect some high-level data about each firm that carries out work within the scope of the regulations, its customers and the services it provides. The responses will allow the Society, as an authorised AML supervisor, to develop an AML risk profile of each firm currently supervised, and of the profession as a whole. This will inform its risk-based approach to AML supervision moving forward.

As part of the new, compulsory process, all firms will be required to upload their own firm-level risk assessment in addition to the completed questionnaire. This is to identify and assess the risks of money laundering and terrorist financing which may affect their business. This firm level risk assessment is an essential part of the AML certificate submission and is key to determining how firms apply a risk-based approach and put the right policies and procedures in place to ensure AML compliance.

The Society recommends that firms carry out their AML risk assessment in advance of the new certificate process being rolled out from 22 October 2018.

To help members meet these new requirements, it has updated its website and expanded the resources available. These include:

  • example risk assessment templates;
  • Treasury-approved UK legal sector guidance;
  • AML good practice guides;
  • NCA suspicious activity reporting information;
  • information on how to spot fake identification documents.

Members will be kept updated on the new online process, which is due to start in October. Please look out for AML update emails.

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