money laundering (AML): Does the Law Society have any advice on how to verify clients who are unable to produce the usual documents?
I am the Money Laundering Reporting Officer (MLRO) of a firm mainly conducting regulated work, although we do identify all our clients. Fee earners sometimes approach me with the question of how to verify clients who are unable to produce the usual documents. For example, immigration clients are often unable to provide standard documentation such as passport, utility bill etc. Does the Law Society have any advice in these circumstances? Yes. Sometimes clients are unable to provide standard verification documents. The purpose of the regulations is not to deny people access to legal services for legitimate transactions but to mitigate the risk of legal services being used for the purposes of money laundering. You should consider whether the inability to provide you with standard verification is consistent with the client’s profile and circumstances or whether it might make you suspicious that money laundering or terrorist financing is occurring. Where you decide that a client has a good
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