AML Toolkit
This page provides links to the key legislation and guidance documents for AML in the legal sector, as well as our templates for risk assessments at the practice unit, matter and client level.
Legal Sector Affinity Group (LSAG) Guidance
- Legal Sector Affinity Group (LSAG) Anti-Money Laundering Guidance for the UK Legal Sector (Part 1)
- Published January 2021, approved by HM Treasury July 2022, updated March 2023.
- LSAG AML Guidance Part 2a: AML Guidance for Barristers and Advocates
- Approved by HM Treasury July 2022
- LSAG AML Guidance Part 2b: AML Guidance for legal professionals providing Trust or Company Services.
- Published April 2021 and approved by HM Treasury July 2022.
- LSAG AML Guidance Part 2c: AML Guidance for legal professionals offering Notarial Services.
- Published April 2021 and approved by HM Treasury July 2022.
- LSAG Advisory Note – Preventing Money Laundering During COVID-19
- LSAG Breach Reporting Note
- LSAG Guidance Note - Remote Working, Client Interaction, associated use of AML technology and Impacts of economic instability
- Published July 2022
- Legal Sector Affinity Group (LSAG) – Advisory Notice - Chinese underground banking and funds from China
- Legal Sector Affinity Group (LSAG) - Addendum to the 2023 version of LSAG's guidance
- Published December 2023
Financial Action Task Force (FATF) guidance
- The Financial Action Task Force released updated Risk Based Approach Guidance for Legal Professionals in June 2019.
- FATF Report – Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals
- FATF Report – Guidance for a Risk-Based Approach Guidance for Legal Professionals
- FATF Report – Guidance on Risk-Based Supervision
- FATF Report - Risk Based Approach guidance for the Real Estate Sector
- FATF Report - Guidance on Beneficial Ownership of Legal Persons
- FATF Report - Guidance on Misuse of Citizenship and Residency by Investment Programmes
Specific identification and verification guidance
How might you or your colleagues spot fake ID documents at client take-on stage?
One way would be to compare and contrast documentation presented against those you know are definitely genuine. This may be using your own photo-card licence or passport to compare against. Also, helpfully, the Passport Office, the DVLA and utility bill providers all provide information on security features, formats and layouts of their bills or issued documents on their websites.
You can find examples and useful links below:
Main energy providers (for utility bill examples – other utility providers may have similar)
Government agencies
- Passport office basic passport checks
- Passport office – new passport design
- DVLA information on driving licences
The Home Office also gives Guidance on Examining Identity Documents.
Other guidance
- Good practice in developing AML Policies and Procedures
- Joint Money Laundering Steering Group (JMLSG) – Guidance on Client Accounts for Banks
- Companies House PSC Discrepancy Reporting Information Apr 2022
- Cryptocurrencies - Risk Assessment & Source of Funds/Wealth Considerations in the context of Conveyancing Transactions
- Changes to domestic PEPs
- Source of Funds and Source of Wealth: What you need to know
- AML and Geographical Risk
- AML Spotlight: Human Trafficking
- AML Spotlight: Terrorist Financing
- AML Spotlight: Holistic Customer Due Diligence
- AML Spotlight: Training
- AML Spotlight: Regulation 21 - Internal Controls
Our AML Round Ups
Supervisory assessments & Annual reports
Supervisory Assessments
Annual Reports:
Thematic Reviews:
- AML Thematic Review of Suspicious Activity Reports - initial findings - 2024
- AML Thematic Review of Policies, Controls & Procedures 2023
- AML Thematic Review of Trust or Company Service Provision (TCSP) 2020
AML inspection information:
Refreshed Sectoral AML Risk Assessment
We have carried out a new, refreshed and far more detailed assessment of AML risks, tailored to the circumstances, demographic and context of the Scottish profession. The Money Laundering Regulations require that our members use this information when carrying out their own money laundering and terrorist financing risk assessments.
Financial sanctions FAQ
Following the invasion of Ukraine by Russia and the resulting sanctions and other restrictions imposed by the UK Government, we are providing answers to some of the most frequently asked questions to provide members of the Scottish legal profession, clarification on what is required of them.
AML FAQs
Answers to some of the most frequently asked AML-related queries, to help the legal profession understand the rationale and responsibilities around AML regulations.
AML information for clients
You may find this information sheet for clients useful when explaining your legal requirement to undertake identification verification of clients and 3rd parties.
AML subscription email service
HM Treasury's financial crime team provides a money laundering subscription email service that may be of interest to practice units. The purpose of the service is to allow the Treasury to communicate directly with subscribers when there are important anti-money laundering developments.
Regulators, such as us, have been asked to highlight this service to our member practice units.