Changes to AML Certificate

The 2024 Anti-Money Laundering (AML) Certificate will introduce changes aimed at streamlining the process and reducing the administrative burden on legal practitioners.

The changes are designed to be user-friendly and efficient for firms, with a more straightforward reporting format to save time and reduce complexity.

Adjustments to the 2024 AML Certificate include:

• Value thresholds: we have combined the previous separate bands for residential conveyancing transactions.
• PEPs: the section on Politically Exposed Persons (PEPs) has been removed and PEP-related questions integrated into other sections.
• Removal of some questions: other internal data sources will be used where possible and appropriate.
• LSAG Compliance Principles: LSAG Key Compliance Principles have been added to Section 2, including questions on PWRAs, duties/responsibilities, r.21 audits, SoF/W, and record keeping. These are designed to be straightforward yes/no answers.
• Higher Risk Industries: the list of higher risk business industries has been updated to reflect changes in LSAG and our Sectoral Risk Assessment.
• Other conveyancing: the section titled Other Conveyancing has been removed, with questions integrated into other sections.
• User-friendly adjustments: we have removed the need to complete sections with ‘0s’, if the question is not applicable to the practice’s circumstances.
• Non-face-to-face transactions: questions on non-face-to-face transactions have been removed. This is due to the reduced risk associated with this delivery channel and increased use of technology to mitigate any residual inherent risks associated with these types of transactions.
• SAR section: we have added a question in the SAR section on internal processes, as well as requesting figures on DAMLs.

The core principles and the objectives of the AML certification remain unchanged:

1. It is a crucial tool for our statutory obligation to deploy a risk-based approach to our AML supervision.
2. It is a questionnaire about your products, services, clients and the way you deliver your services.
3. It is compulsory for all practices that fall within scope of the AML regulations to complete the certificate.

If practices have any questions on the changes, please contact the AML team at aml@lawscot.org.uk.