Having worked in several different law firms over the past 10 years, it has been interesting to see how each firm has dealt with conflict checking differently.Many medium to large law firms have teams running conflict checks for the firm. From my experience however in many of these firms the…
The AML legislation imposes a positive duty on lawyers, in certain circumstances, to report any suspicion that their client is engaged in money laundering. Given that such a duty is, on the face of it, in conflict with fundamental obligations on solicitors to act in the best interests of their…
In this series, I cover my Top Tips for AML Compliance, here are the first 10……1) Evidencing you have taken your supervisor’s risk assessment into account when preparing your own. All firms must have regard to their supervisor’s risk assessment when preparing their own. (Reg18(2)) Make sure it is mentioned…
Human trafficking is one of the fastest growing illegal enterprises in the world (after drug trafficking). The statistics show the true extent of the problem – a joint report produced by FATF and the Asia/Pacific Group on Money Laundering (AGF) in June 2018 linking money laundering and human trafficking showed…
So, we all knew that the ICO had been equipped with a fine set of gnashers by the GDPR and DPA legislation. What we didn’t know was what it would take to get them to bare them or actually use them. Or what the consequences of an ICO mastication would…
I attended the Ark Group Annual AML Conference in London yesterday to speak on the panel about the challenges for MLROs who are also fee earners in their firm.The session posed questions to the audience, and we, the panel, put our two penneth in.Joining me on the panel was Alex…
(Originally published on Ark Group’s Website) With the SRA reporting last week that 44% of the firms they recently visited in an Anti-Money Laundering (AML) thematic review have been referred through to their disciplinary procedure, the level of compliance in law firms has again been called into question…There have also…
As part of the recently launched Teal Compliance Officer Training Programme, I ran a webinar session running through all the requirements in relation to Price Transparency and the impact it is having on firms. The first thing I would say is that the new rules create a market of opportunity…
Filing Suspicious Activity Reports (SARs) should be a priority for all law firms when presented with circumstances that alert them to the potential for money laundering.But the very word "suspicious" is – in itself – problematic: lacking clear definition. Money laundering is showing absolutely no signs of diminishing, but in…
We’re nearly a year since the frantic preparations for GDPR. How is it all going? Should we be checking? Should we audit?Why do I need to complete an audit?An audit allows an Organisation to understand whether it is complying with the requirements of the Data Protection Act 2018, GDPR and…
