This article was originally published in 2011.
From speaking with many money laundering reporting officers (MLROs) over the years, it seems that few actively sought out the role, but were often chosen because:
- their area of the practice was likely to generate the most anti-money laundering compliance requirements;
- they were the firm’s expert on legal professional privilege;
- it just seemed to fit with the other management roles they had; or
- they missed the partnership meeting were the role was allocated and were unable to come up with a good excuse to give it to someone else.
While the role may seem daunting at the outset, the Law Society provides a lot of support to help you master the topic and provide good quality advice to your firm and your clients.
Within this new regular feature, the Law Society’s policy team, Practice Advice Service and Money Laundering Taskforce (all of whom are proud AML anoraks) will seek to highlight the resources available to you, give you tips on how to manage fee earners' and management's expectations, and help you avoid some of the common pitfalls for newcomers.
With any luck some of our enthusiasm for the subject may rub off on you and you may come to agree that anti-money laundering can be one of the most interesting areas of legal practice on offer.
Where to begin
1. Make sure you are registered as the firm’s MLRO with the Solicitors Regulation Authority (SRA)
Under the Money Laundering Regulations 2017 each firm must inform the SRA of the identity of its MLRO, which can be done via the SRA website. This requirement also applies to the firm's Money Laundering Compliance Officer.
2. Sign up for the Law Society's AML e-newsletter
The fact that you are reading this article increases the chances that you are either already signed up to the e-newsletter or that someone has sent you a copy. The e-newsletter will keep you up to date on legislative changes, new methodologies and training opportunities.
3. Read the legal sector AML Guidance
We appreciate that the guidance is around 150 pages long, which may seem quite daunting. However, as MLRO, with legislative responsibility for your firm’s compliance, it really is important that you read it through at least once to familiarise yourself with the material. We have tried to ensure that it is written in plain English and follows a very logical and practical format.
You will need to refer to the guidance on a regular basis, so make sure that the link to the guidance is saved in your favourites folder in your internet browser or is linked from your intranet.
4. Sign up to the introductory online courses
While you may have undertaken AML training before, as MLRO you will have new responsibilities and a wider range of decisions to make about the processes your firm will adopt.
The Law Society has developed online and face-to-face courses specifically designed for MLROs and their deputies as well as fee earners in law firms to ensure everyone has a clear understanding of the issues you will now need to deal with. Our AML toolkit, available through our online bookstore, also offers a comprehensive mixture of policies and checklists to help you put into place effective AML policies.
Additionally, we provide free face-to-face training, for example through our MLRO networking events. Information about these is available on our events page, so do check in regularly.
It is always best to build knowledge in stages so that you do not get information overload.
5. Keep the AML Helpline number within easy reach
The Law Society’s AML Helpline receives over 3000 calls a year from practitioners seeking assistance with AML compliance. They can help you navigate the AML guidance, consider practical ways to obtain client due diligence information or verify the source of funds in particular cases and review your reporting obligations.
They can be contacted on: 020 7320 9544 or by email at: email@example.com between 09:00 and 17:00 on weekdays.
When emailing in queries, please remember to respect client confidentiality and refrain from providing the client’s actual names, bank account numbers, correspondence.