As a lawyer you could be forgiven for thinking that money laundering regulations are evolving every day.
It is crucial for CQS accredited firms to diligently uphold their AML Policies controls and Procedures. This involves ensuring that all documentation is kept up to date in line with regulatory changes to optimise full compliance.
Everyone in the conveyancing profession, including its regulators, must ensure that AML processes are robust. The SRA and CLC will face even greater scrutiny to review compliance among firms regularly and apply pressure through its Thematic Review regime.
If you are a CQS accredited firm are prepared for a review of your AML policy? Have you conducted, or had an external Independent AML Audit? Is your AMLPolicies, Controls and Procedures in good order? Do you, and more importantly, your staff know your AML risks?
When it comes to a CQS AML Policy it will need to be reviewed and updated. Below are some examples of some some of the sections added or updated to The CQS Anti-Money Laundering Policy by Lexsure in 2023:
Duty to Identify Beneficial Ownership
Registered Charities
High-risk Third Countries
5MLD Requirements – Reporting on a Company’s Beneficial Ownership
Submitting Better Quality Suspicious Activity Reports (SARs)
Chinese underground banking and funds from China
Financial Sanctions
2023 LSAG Guidance + Checklists