Anti Money Laundering (AML): We are a niche litigation firm. Are we obliged to conduct Customer Due Diligence on our clients and appoint a Money Laundering Reporting Officer?
We are a niche litigation firm. We are unclear as to our obligations under the Money Laundering Regulations 2007. Are we obliged to conduct Customer Due Diligence on our clients? Are we also obliged to appoint a Money Laundering Reporting Officer? Regulation 20 of the Money Laundering Regulations 2007 (the regulations) requires the regulated sector to have certain systems in place. The Treasury has confirmed that participation in litigation is an activity which is not covered by the regulations and you are therefore not obliged to identify and verify your clients. Nor are you obliged to appoint a Money Laundering Reporting Officer (see chapter 1 of the Law Society’s Anti-money laundering practice note). However, you should still consider how these systems can assist you to comply with your obligations to report suspicious transactions in accordance with the Proceeds of Crime Act 2002 and the Terrorism Act 2000 (see chapter 3 of the practice note). As the firm specialises in litigation,
