AML Certificate Results 2021

Our Anti-money Laundering Risk Manager, Bob Clark provides an update on the key insights and analysis from the data you provided in the 2021 Anti-money Laundering (AML) Certificate.

The AML Certificate is a mandatory annual questionnaire posed to all practices under the scope of the Law Society's AML supervision. The certificate provides the Society's AML team with an indication of inherent AML risks posed to each in scope practice.

The AML team continue to maintain a robust approach to our risk-based AML supervision and once again we are thankful to all participating practices who submitted a 2021 AML Certificate.

We now feel that the AML Certificate process is a well embedded and established tool within the supervised population which allows the information gathered to continue help when shaping, analysing, gaining insights, and identifying trends related to money laundering in the legal sector and across our supervised member population.

Utilisation of information contained in certificate responses along with information and knowledge additional sources allows the AML team to satisfy our supervisory obligation in relation to the risk assessment of our members.

For the 2021 version of the certificate the AML team were keen to keep this largely unchanged from the previous year.

We retained much the same layout: set out in a data analysis method, and also kept the majority of questions the same with slight amendments or condensing of particular risk types. We hoped that by doing so, we would ensure that information gathered from the practices is reliable and as in depth as possible.

This also allows us as a regulator to successfully review the collected data and provide accurate risk assessments of individual practices along with reviewing the data in a broader sense in order to identify emerging risks, trends, or anomalies.

The infographic below highlights some of the key, high-level information gathered and also puts it in to context alongside our refreshed Sectoral Risk Assessment.

Please do review the ‘Points to consider’ along with the additional information outlined in each section and give thought to whether or not your practice is confident in its approach to AML.

Anti-money laundering continues to be an ever-growing requirement within the Scottish legal sector and the AML Certificate remains a crucial tool in our approach to risk based supervision, each individual practice has a responsibility to ensure we use that tool well which is a reason that the data submitted must be accurate.

Further reading and guidance relating to AML within the legal sector and compliance within your firm can be found on the AML pages of our website, please do familiarise yourself with this content and I hope you will also look out for further information relating to AML and the AML Infographic figures in The Journal, our fortnightly member email Lawscot News and on social media channels.