Law firm (sole practitioner CQS accredited) calls with AML concerns about a potential client. The client had a significant sum of money in an overseas account which was not in the client’s name. The firm made further enquiries with the client regarding the funds and requested additional evidence to satisfy source of funds/wealth requirements.
The practitioner, also the MLRO, was advised of the current AML requirements of the Anti-Money Laundering & Combating Terrorist Financing Code and Money Laundering Regulations 2017.
It was concluded that as the prospective client was unable to provide the practice with satisfactory source of funds/wealth evidence and therefore they would be unable to act for the client in this matter. The practice was of the opinion that as the instruction was outside the usual remit of their source of work as per their firmwide risk assessment, they would not act on this matter and thus ended the retainer.
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