AML registration open Firms must be registered by 26 June 2018
An ever-increasing focus on anti money laundering (AML) controls within the legal profession has seen the introduction of new AML requirements for both the Law Society and the Scottish solicitors.
As part of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, all beneficial owners, managers and officers of Scottish law firms must register for approval with the Law Society by 26 June 2016. The Law Society, as a HM Treasury-appointed AML Supervisor, is required to collect, retain and provide anti-money laundering related information about our members.
The Law Society has launched an online AML registration portal for firms to complete the registration process by 26 June 2018. All submissions must include disclosure documents and to avoid any delay in your firm's AML registration, please apply for these before 8 June 2018.
Ian Messer, Director of Financial Compliance at the Law Society of Scotland said: “The new AML requirements bring a huge amount of change for solicitors and it’s vital for our members to keep up to date. These are mandatory and non-compliance could potentially result in criminal penalties for individuals or even the closure of the firm.
“As the AML Supervisor for Scottish solicitors, we are committed to educating and supporting our members as much as possible to ensure they can take the necessary steps to ensure compliance and prevent the Scottish legal system being used to launder the proceeds of crime.
“We will continue to send regular updates on the new AML requirements and solicitors can also check our website, where there is a wealth of information on how to comply. We have also published helpful information on the new registration process and what to do before submitting your application, such as ensuring you have the necessary disclosure documents, by the deadline on 26 June.”
The Society intends to recover AML supervisory cost, such as the OPBAS fee and staff costs associated with AML supervision, from partners and directors of practice units doing work within scope of the money laundering requirements. More detailed information, including how this will affect the Accounts Fee, will be published in due course.
For more information see the AML section of our website or contact us at AMLregistrations@lawscot.org.uk
To register your firm, sign in to the members’ area of the website and click on ‘AML Registration’.
Your firm must also submit current (up to six months old) Basic Disclosure Scotland certificates (or DBS check if in England and Wales) for all beneficial owners (partners), managers and officers of the firm.
If you do not have up to date disclosure certificates please apply as soon as possible to ensure you submit your AML registration application by 26 June 2018.
If no application is made by this date, the individual will NOT be able to continue as a beneficial owner, manager or officer of the firm, and may be liable for criminal penalties.
Firms with 10 or more partners can appoint a designated person to prepare the information for review and submission by the MLRO. Details of a firm’s designated person, including date of birth, current contact details and (if a solicitor) their solicitor registration number, should be emailed to the Law Society as soon as possible at AMLregistrations@lawscot.org.uk
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