AML round up: February 2025

It's vital for solicitors to be aware of the latest anti-money laundering (AML) developments. Catch up below on all the latest AML news and developments for the legal sector, including an introduction to the Law Society's new Head of AML, what our AML team has been up to and updates from HM Treasury and the National Crime Agency.

Suspicious Activity Reports (SARs) thematic review

We're undertaking a comprehensive thematic review of SARs in collaboration with the National Crime Agency (NCA). Initial findings have revealed that, while positive procedures are in place across many firms, there is a pressing need for enhanced support and guidance, particularly in the areas of training and understanding the threshold for suspicion.

A significant focus of the review was on Defence Against Money Laundering (DAML) reports. The findings highlighted a mixed understanding among Money Laundering Reporting Officers (MLROs) on the distinction between information SARs and DAMLs.

We're currently conducting the second phase of the thematic review, which is examining the quality of SARs submitted to the NCA. This crucial step aims to ensure that the legal sector is effectively contributing to the national effort against money laundering. The full results of our review will be out soon.

Have you seen our AML Spotlight blog series on key topics and concerns? Catch up below and keep an eye out for our next blog, which will focus on Reliance and Reporting of Discrepancies on Registers.

• Faculty visits: In September 2024, our AML Risk Manager Stewart Rowles conducted a presentation to the Royal Faculty of Procurators in Glasgow covering regulatory compliance updates and provided advice on identifying and mitigating anti money laundering risks.
• Trainees – continued professional development (CPD): AML Risk Managers Emma Cairns and Dale Trahms delivered an Introduction to AML presentation to trainees as part of their CPD in October 2024.
• Society of Law Accountants Scotland (SOLAS) presentation: In August 2024, Dale and our former AML Risk Manager Jenni Rodgers delivered a presentation to SOLAS members, focusing on source of funds and holistic customer due diligence.
• Suspicious Activity Report (SAR) webinar: Dale delivered a webinar to our members, covering our initial SAR thematic review findings, along with guidance on the importance of conducting holistic due diligence and the link between due diligence collected and submitting a high quality SAR.