AML Certificate results 2019

Our Anti-Money Laundering Risk Manager, Fraser Sinclair provides an update on the key insights and analysis from the data you provided in this year's AML Certificate.

With ever-increasing attention on financial crime across the UK, it remains as important as ever that we continue to embed a risk-based approach to AML supervision which is engaged and robust, while remaining fair and evidence-based. In line with this, all firms which carry out work within scope of the Money Laundering Regulations return an ‘AML Certificate’ – a questionnaire indicating their exposure to inherent AML risks. The ‘AML Certificate’, alongside other information, allows us to satisfy our supervisory obligation to risk assess all firms, as well as steering our risk based approach.

This year we implemented a data analysis method which was more valid and reliable, but which required a change to the way in which we asked some questions on the AML Certificate. This presented a difficulty for some firms more than others, especially in light of the coronavirus, and I’m extremely thankful to the >99% of firms who returned the AML Certificate by their final deadline.

The richness of the data you provide us in this new style certificate not only means accurate risk assessment of single firms, but allows us to dive into the overall data for whole-population insights – spotting trends and anomalies that we would not otherwise have been able to.

The infographics below show just some of the key high level information from your AML Certificates. I recommend going through the ‘Points to consider’ questions and asking yourself whether you think your firm would need to do anything more in order to be confident in its answers.

I know firms will have heard it before, but Anti-Money Laundering is now a significant consideration for the Scottish legal sector and the AML Certificate is one our most crucial tools in our approach to AML Supervision.

The AML pages on our website contain some great information on AML compliance at your firm and I hope you continue to look out for our AML pieces in The Journal and our recurring ‘AML Roundup’ in LawScot News.

We would like to thank our members for your cooperation in these difficult times, working together, we can help to keep the proceeds of crime out the Scottish legal sector.