Meet our new Head of AML: Gemma Turnbull
Gemma Turnbull joined the Law Society of Scotland in January this year as our new Head of Anti-Money Laundering (AML). In our Q&A, find out more about Gemma, what she thinks is the biggest risk facing the legal profession today and her one piece of advice on AML to all members.
Tell us a bit about your career so far.
Answering this question forces me to recall just how many years I have worked within regulatory compliance, which leads me to remember just how old I am! And that is never a good thing…
While working in branch-based business banking many years ago, I uncovered a money laundering scam, which in turn pulled me into a career focused on economic crime prevention within the legal sector and financial services industry.
My career within the regulatory compliance industry really began as a junior customer due diligence analyst at Lloyds Banking Group, conducting onboarding due diligence checks on high-risk business customers. Then, latterly, I worked within the associated quality check and quality assurance functions.
In more recent years, I have specialised in the set up of anti-money laundering / customer due diligence teams, both within the UK and on a global scale, and led training and advisory teams who provide AML subject matter advice to partners, relationship managers and senior management.
Throughout my career I have worked to help firms comply with the money laundering regulations and integrate these obligations into the processes utilised within busy operational environments.
What motivated you to join the Society as Head of AML?
I have frequently heard of the regulatory compliance field being compared to marmite – you either love it or you hate it. I genuinely enjoy working in this industry and want to help firms meet their obligations and protect themselves.
I fully understand and appreciate the challenges faced by firms in meeting their AML requirements throughout the client lifecycle. However, I have also seen the impact on firms when they are targeted by those wanting to launder money through legitimate businesses.
Ensuring compliance with anti-money laundering requirements is not always straightforward, especially as the risks faced are continuously evolving, but the requirements are there to protect legitimate individuals and businesses.
What is the biggest risk currently facing the legal profession?
In my opinion, the biggest risk to the profession is also the one thing that has the potential to bring revolutionary positive change and that is artificial intelligence (AI).
The recent advancements in AI have massive implications in the fight against money laundering, especially in terms of the production of fake identification and evidence.
However, an example of the flip side of this is that advancements in technology have shown the potential for significant efficiency gains through activities such as automated document drafting.
If you could give one piece of advice to members about AML, what would it be?
If something doesn’t seem right to you, trust your instincts.
AML compliance isn’t solely about getting ID and source of wealth information to tick a box. It is imperative to apply a 'makes sense' check to ascertain if what you are being asked to do seems correct given the circumstances.
For example, does the coffee shop in the West End of Glasgow need a storage facility in Jakarta? Maybe it does and this is totally legitimate, or maybe this is a red flag that something is amiss.
What keeps you busy outside of work?
Without a doubt, my family, my friends and (most importantly) my golden labrador Lomond – otherwise known as the most spoiled dog in central Scotland! I also love watching a good crime drama and, when I can, spending time in the kitchen.

Anti-money laundering
The fight against money laundering and counter terrorist financing - the role of the legal profession.