AML Certificate

Yes, under Accounts Rule B9, completion of the AML Certificate is compulsory. The usual process for non-compliance will be followed where necessary, which may result in referral of a complaint to the Scottish Legal Complaints Commission.

No. The AML registration process, whereby firms must keep us informed of Partners, Beneficial Owners etc, is distinct from the AML Certificate.

Being up-to-date with your AML Registrations is not the same as being covered for your AML Certificate. You must still complete the AML Certificate process annually.

If your firm does not undertake any of the prescribed activities within the Money Laundering Regulations 2017 and you have not yet been granted an exemption, but believe you should be, please complete an exemption declaration form.

No, you should not complete the certificate if your registered office is not in Scotland.

We require all practices within the scope of the AML regulations to complete an AML Certificate for the period that they have been operating within the 'relevant period'. These practices are then required to complete the AML Certificates in full each year thereafter.

The MLRO should sign in to the members' area of our website using their own credentials, then select AML from the menu on the left hand side. They should then select the AML Certificate tab, read the notes and scroll down to begin completing the form.

Please remember to use the 'Select Firm' box to confirm the practice that you are completing on behalf of.

For the 2025 AML Certificate, the deadline for submission is Friday, 26 June 2026.

The most likely reason that you cannot submit your certificate is that you have not completed all of the mandatory questions.

Yes, a Word copy of the certificate is available to download above.

The time taken to complete the certificate will be dependent on a range of factors within your business. It is recommended you begin completing the certificate as soon as possible.

No, the AML Certificate can be completed over a number of sessions.

Accuracy is important when completing the certificate, as the answers you provide allow the Law Society to profile the risks inherent across the sector and at individual practice level. It also supports us in adopting a risk-based approach to our supervisory inspection regime, minimising impact to both the Law Society and those practice's selected for inspection

The information we request is information we expect practice's to collate in order to satisfy regulatory and practice rule requirements, and will allow practice's to demonstrate good AML control and governance to the Society in line with LSAG Guidance. Firms should therefore be able to answer the questions posed with a high level of accuracy.

To help you, please familiarise yourself with the AML Certificate guidance available on this page.

If you have further questions, please contact us at [email protected].

The MLRO must submit the form. A designated person may be set up to enter information into the portal, but the MLRO remains responsible for the information entered and must submit the form. The MLRO should login to the portal using their individual details, rather than firm login details. 

The MLRO should email [email protected] to name a designated person. They should provide the full name, company, business address, phone number, email address and date of birth of the designated person. That person will then be assigned specific login details to allow them access to the form.

No, you do not need to submit a PWRA with your AML Certificate.

Previously, part of the AML Certificate process was to provide a copy of your PWRA along with your AML Certificate. However, this is no longer a requirement.

Nevertheless, the requirement to maintain a PWRA remains a statutory obligation within the Money Laundering Regulations 2017 (Reg. 18) and you should have one in place.

No. Under our memorandum of understanding with the Solicitors' Regulation Authority (SRA), firms that have a head office in Scotland come under Law Society of Scotland supervision and so won’t need to complete the SRA's AML questionnaire. Read more about our unified approach here.

The responses will be used to assign inherent AML risk profiles across our supervised population. An inherent AML risk profile is a consideration of your firm’s AML risk before any mitigating controls are put into place and is therefore not a reflection of, or judgment on, your policies, controls and procedures or your firm’s ability to mitigate risk. The results of any analysis will inform our risk-based approach to supervision.

The data is stored in our internal data management system, along with all other information about firms that we hold. The data is also drawn down into a protected Excel dashboard platform to allow any risk analysis to take place. More information can be found in our privacy policy.

We will store data for up to five years for each AML Certificate return.

We do not intend to share your data outside of the regulatory functions of the Law Society of Scotland. However, where our regulator (OPBAS) carries out any audit of our files, it may have sight of the data as part of that audit function. Collated or anonymised data may be used to educate or inform governmental departments as well as our membership. At all times we remain bound by the reporting obligations contained in the Proceeds of Crime Act 2002 and other legislation.