Scottish firms’ AML-related work rises to over £800 million

Analysis of the Law Society of Scotland’s latest anti-money laundering (AML) Certificate shows that regulated practices in Scotland reported almost £819 million in fees in 2024 from work within the scope of AML regulations.

The data indicates that supervised firms declared £818.9 million in gross fees from AML‑related work, representing a 16.9% increase on 2023.

Conveyancing continues to account for the largest share of these fees and remains the area of greatest money laundering risk in the Scottish legal sector.

Commenting on the findings, Gemma Turnbull, Head of the Law Society’s AML Team, said: “We know that completing the AML Certificate requires significant effort and we appreciate the time and dedication practices put into collating this information. We hope the data provides valuable insights into our AML landscape and helps identify the risks across different areas of practice. At the same time, accuracy continues to be a challenge. Our team has increased its testing and has engaged directly with practices where discrepancies have been found. The value of this analysis will always depend on the quality of the information supplied.

“It is important to remember that money laundering is never a victimless crime. It enables and funds serious offending, including human trafficking, kidnapping, extortion, corruption, and fraud, and can contribute directly to human rights abuses.”

Spotlight on conveyancing

In 2024, 61 practice units reported conveyancing transactions linked to China, compared with 24 in 2023 and 84 in 2022. China imposes strict restrictions on moving capital overseas, which has fuelled the use of shadow banking and unregulated money service dealers. The Society continues to review transactions where funds originate from China to mitigate the risks associated with Chinese Wire Rules.

Read more from the Legal Sector Affinity Group: LSAG Advisory Notice on Chinese Underground Banking and Funds from China.

Conveyancing matters involving cryptocurrency remain relatively uncommon but continue to feature in practice. In 2024, 20 practice units reported 38 matters involving crypto‑derived funds, up from 25 matters across 18 practice units in 2023. While volumes remain low, the risks are inherently high. Any practice deciding to accept such funds should document the rationale in detail within the client and matter risk assessment, ensuring alignment with the practice’s stated risk appetite. Further guidance is available in our cryptocurrencies update.