You are here:
  1. Home
  2. News
  3. Blog
  4. Do money launderers have holidays off? 5 red flags for smaller firms to look out for

Do money launderers have holidays off? 5 red flags for smaller firms to look out for

18 December 2017

It is that time of year again, we are all feeling festive, thinking of relaxing at home over the Christmas period with mince pies, chocolate and turkey! But what are the criminals looking forward to? 

Reduced numbers of staff in law firms, less focus on transactions while we’re recovering from the Christmas party, or hoping to slip through your checks in the very busy period when people want to be in their new house before Christmas.

It is very difficult to predict how a money launderer might target your firm, but here are 5 red flags you should be on the lookout for.

1 Clients with no obvious reason to instruct you

We always ask clients 'Where did you hear about us?' We know that many clients come as a result of a recommendation from a former client or an introducer of work. Some firms market for new clients, but if you get a new client, who has come to you without any obvious connection, ask yourself why. Is it because the client is targeting your firm because they think you won’t spot that they are laundering money?

2 Secretive clients

Firms should have client due diligence procedures designed to 'know your client'. A client who is reluctant to share information with you, may be a red flag for money laundering. Most organisations will ask for some sort of identification, and in some cases financial history. A person who refuses to provide this information may be trying to hide that they are impersonating someone else, or that they have illegitimate funds they do not want you to discover. You should consider whether their refusal is at all suspicious, and if so, consider reporting to your money laundering reporting officer.

3 Too much information

Conversely a client who provides all the information you need without being asked may also be a red flag. A criminal wanting to launder money through your firm is likely to know what information you will ask for. In order to rush the matter through they may provide this information unprompted. Unless your client is a frequent user of legal services, it may be unusual for them to know what you need, and if it is volunteered you should consider whether this is suspicious.

4 Third party funding

Using third party funds in a matter is becoming more and more common as the value of property increases. It is quite often the client’s parents who are gifting the money to the client, but be careful, criminals try to launder money through third party funding because they think you will only carry out due diligence on the client, and not a third party. If you have a third party funder, you should consider the risk of money laundering and whether you should conduct any checks on them and the source of the monies.

5 Last minute changes to funding

Where we do see criminals trying to launder money through solicitors firms, particularly in conveyancing transactions, they will often try and get around checks by changing the source of the funding at the last minute. This doesn’t give the lawyer time to do proper due diligence on the funds before completion.

When getting ready to complete a transaction, it is useful to revisit your client due diligence documents and check that the money you have received is from the source you were expecting. If not, you should make enquiries and consider whether you are suspicious that this is money laundering.

Criminals don’t stop over Christmas, so neither should your AML procedures. Check out our red flags for money laundering . You can also get support from our dedicated free and confidential AML practice advice line staffed by solicitors on 020 7320 9544.

Views expressed in our blogs are those of the authors and do not necessarily reflect those of the Law Society

Concerned about an AML issue? Unsure about AML regs? Solicitors can confidentially discuss it with our Practice Advice Service solicitors. Call on 020 7320 9544 or email

Explore our legal sector guidance and anti-money laundering resources

Tags: anti-money laundering

About the author

Amy Bell is the author of the Law Society’s Anti-Bribery Toolkit. She is the chair of our Money Laundering Task Force, where she represents the solicitors’ profession to the government and in Europe. Amy is a compliance consultant with 12 years’ experience of working with law firms. She launched Amy Bell Compliance Ltd in 2017

  • Share this page:

Adam Johnson | Adele Edwin-Lamerton | Ahmed Aydeed | Alex Barr | Alex Heshmaty | Alexa Lemzy | Alexandra Cardenas | Amanda Carpenter | Amanda Jardine Viner | Amy Bell | Amy Heading | Andrew Kidd | Andy Harris | Anna Drozd | Annaliese Fiehn | Anne Morris | Anne Waldron | Asif Afridi and Roseanne Russell | Bansi Desai | Barbara Whitehorne | Barry Wilkinson | Becky Baker | Ben Hollom | Bob Nightingale | Caroline Marlow | Caroline Roddis | Caroline Sorbier | Catherine Dixon | Chris Claxton-Shirley | Christina Blacklaws | Ciaran Fenton | CV Library | Daniel Matchett | Daphne Perry | David Gilroy | David Yeoward | Douglas McPherson | Dr Sylvie Delacroix | Duncan Wood | Eduardo Reyes | Elizabeth Rimmer | Emily Miller | Emily Powell | Emma Maule | Gary Richards | Gary Rycroft | Graham Murphy | Gustavo Bussmann | Hayley Stewart | Ignasi Guardans | James Castro Edwards | Jayne Willetts | Jeremy Miles | Jerry Garvey | Jessie Barwick | Joe Egan | Jonathan Andrews | Jonathan Fisher | Jonathan Smithers | Julian Hall | Julie Ashdown | Julie Nicholds | Justin Rourke | Karen Jackson | Kate Adam | Katherine Cousins | Kaweh Beheshtizadeh | Kayleigh Leonie | Keiley Ann Broadhead | Kerrie Fuller | Kevin Poulter | Larry Cattle | Laura Bee | Laura Devine | Laura Uberoi | Leah Glover and Julie Ashdown | Leanne Yendell | LHS Solicitors | Lucy Parker | Maria Shahid | Marjorie Creek | Mark Carver | Mark Leiser | Markus Coleman | Martin Barnes | Matt Oliver | Matthew Still | Melissa Hardee | Neil Ford | Nick Denys | Nick O'Neill | Nick Podd | Nikki Alderson | Oz Alashe | Patrick Wolfe | Paul Rogerson | Pearl Moses | Penny Owston | Peter Wright | Philippa Southwell | Preetha Gopalan | Rachel Brushfield | Ranjit Uppal | Richard Coulthard | Richard Heinrich | Richard Messingham | Richard Miller | Richard Roberts | Rita Oscar | Rob Cope | Robert Bourns | Robin Charrot | Rosy Rourke | Saida Bello | Sally Azarmi | Sally Woolston | Sam De Silva | Sara Chandler | Sarah Austin | Sarah Crowe | Sarah Henchoz | Sarah Smith | Shereen Semnani | Sofia Olhede | Sonia Aman | Sophia Adams Bhatti | Sophie O'Neill-Hanson | Steve Deutsch | Steve Thompson | Stuart Poole-Robb | Susan Kench | Suzanne Gallagher | The Law Society Digital and Brand team | Tom Ellen | Tony Roe Solicitors | Umar Kankiya | Vanessa Friend | William Li