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Anti-money laundering: Reporting your concerns

26 February 2019

This guidance helps to explain the role of the Law Society to members who may wish to report potential money laundering or breaches of the Money Laundering Regulations 2017 in which your colleagues, firm or another person might be taking part.

The guidance is directed at sole practitioners and those working in firms regulated by the Solicitors Regulation Authority (SRA).

Members of the public should contact the police, the National Crime Agency (NCA) or the SRA.

This guidance does not address responsibilities to implement anti-money laundering procedures or assist with deciding whether a report should be made to the NCA about a client.

For practical advice on the UK’s anti-money laundering (AML) regime and your compliance obligations, please see our AML guidance for the legal sector or visit our AML page.

Reporting to the Law Society

The Law Society delegates all regulatory and enforcement functions to the Solicitors Regulation Authority. Accordingly, we cannot take reports from you on AML or other issues.

If you did disclose certain information to the Law Society, we may be subject to our own legal obligations to make a report to the SRA or to submit a suspicious activity report (SAR) to the NCA.

We would respect your anonymity and/or confidentiality where there was no legal need for us to disclose your details onwards.

We strongly encourage reports of wrongdoing to be made to the appropriate authorities. Please find our guidance on who to report to below.

Reporting to the organisation best-placed to assist you

Reporting internally

You should first consider reporting suspected wrongdoing through the channels available to you at your firm.

Your firm’s whistleblowing policy, should it have one, will assist you in determining whether and how you can report your concerns internally.

If your concerns relate to possible breaches of sections 327, 328 and 329 of the Proceeds of Crime Act 2002 at your firm, your money laundering reporting officer (MLRO) may be best-placed to determine what to do with the information.

Reporting to the SRA

Chapter 10 of the Code of Conduct states that solicitors must report serious misconduct by any person or firm authorised by the SRA, or any employee, manager or owner of such a firm to the SRA.

This includes conduct relating to a criminal offence such as money laundering, and conduct in relation to breaches of the Money Laundering Regulations 2017.

To make a report to the SRA, please visit the SRA’s whistleblowing page.

Reporting to the National Crime Agency

Part VII of the Proceeds of Crime Act 2002 mandates reporting knowledge, suspicion or reasonable grounds for knowledge or suspicion of the money laundering offences listed in Part VII.

Such reports must be made directly to the NCA in the form of a suspicious activity report (SAR).

You should refer to your MLRO, who will decide whether a report is necessary.

To make a report to the NCA, please use SAR Online.

Other sources of information

For advice on protection available under the Public Interest Disclosure Act 1998 and the Enterprise and Regulatory Reform Act 2013, contact Protect.


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