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Web Resources for Money Laundering Regulations

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Last updated March 24th.

Guidance Online

  • Institute of Money Laundering Prevention Officers (IMLPO) has its sixth annual conference on Monday 11th and Tuesday 12th May 2009 at the Barcelo Blackpool Imperial Hotel. A key topic this year is "balancing AML obligations, client confidentiality and data protection requirements". Full information on the IMLPO site.

  • The Law Society has highlighted the heavy compliance burdens placed on solicitors as a result of the anti-money laundering regime which applies in the UK and across Europe. Responding to a call for evidence, the Society has encouraged the House of Lords home affairs subcommittee to seek a comprehensive examination of the costs and benefits resulting from the regime. The Law Society has drawn to the committee's attention the fact that no detailed cost/benefit analysis has been undertaken into the effectiveness of either the Financial Action Task Force's recommendations, various European Directives or the UK anti-money laundering regimes. Evidence from solicitors strongly suggests that the regulated sector is spending significantly more on compliance than the UK government is recovering in criminal property. In the face of this apparent lack of proportionality, the Law Society has recommended that:
    i) Governments and international policy agencies should develop a framework to adequately assess the effectiveness of anti-money laundering regimes.
    ii) Governments need to review the effectiveness of their anti-money laundering regimes and look at proportionate ways to reduce the burden on the private sector and to increase the amount of criminal property recovered and criminal activity disrupted.
    iii) Law enforcement agencies and anti-money laundering policy agencies need to continue to provide the private sector with information about money laundering and terrorist financing. This will help the private sector to better understand the warning signs and to comply with their obligations.
    The evidence that the Law Society prepared (PDF, 115Kb) for the House of Lords Select Committee on the European Union – sub committee F (Home Affairs) can be found here.

  • Legal Risk (Solicitors) have a section on their site devoted to money laundering, including links to relevant case reports, a report on Money Laundering Compliance for Defendant Insurance Solicitors, information on a book called Money Laundering Reporting Officer's Handbook: A Guide for Solicitors and a comprehensive set of links to organisations, guidance and resources related to money laundering.

  • ML Solutions 4U Ltd has been set up by Manchester law firm JMW to provide anti-money laundering solutions to the legal profession. The services offered include on-line compliance training, in house training, seminars, AML systems set up and general guidance. In addition the company, in association with CallML, offers help to solicitors on the use and viability of electronic ID verification via the internet.

  • The Serious Organised Crime Agency (SOCA) is a new law enforcement agency created to reduce the harm caused to people and communities in the UK by serious organised crime. In April 2006, it took over the functions of the National Crime Squad (NCS), the National Criminal Intelligence Service (NCIS), the role of HMRC in investigating drug trafficking and related criminal finance and some of the functions of the UK Immigration Service (UKIS) in dealing with organised immigration crime. SOCA is commencing Sector Specific Seminars for Money Laundering Reporting Officers and details of these will appear on the site.

  • The International Bar Association's Anti-Money Laundering Forum website provides access to the most current versions of each EU member states anti-money laundering laws and regulations, direct links to national anti-money laundering authorities information websites and a large amount of related information. The Forum has already expanded the website to cover the 15 accession countries and is in the process of adding all significant jurisdictions around the world. The IBA's main website is here.

  • The Institute of Money Laundering Prevention Officers (IMLPO) was set up in 2001 for the UK's anti-money laundering community and is a broad, cross-representative forum of AML practitioners. It provides a safe environment in which members can share experiences of and opinions on the day-to-day business of combating money laundering. IMLPO has recently broadened its membership beyond financial institutions, to include practitioners from the whole anti-money laundering community. There are now over 160 members, not only from banks, insurance companies etc but also from the new "gatekeepers" such as law firms, gaming companies, accountancy firms and stockbrokers.

  • The Institute of Legal Cashiers and Administrators is very worried that cashiers and administrators are being asked to accept the role of Money Laundering Reporting Officer. "Our concern is that Legal Cashiers and Administrators may not have the necessary knowledge of the law to intervene correctly in a matter, nor the authority within a practice to report infringements of the Money Laundering Regulations 2003. We already know of instances where members of the ILCA have been asked by partners to take on this role and we are extremely concerned for those members. Whilst our training courses can equip staff to spot potential infringements of the Regulations, we do not believe it is right and fair for them to face the penalties associated with the role of the MLRO."

  • Here are some detailed links relating to money laundering regulations kindly provided by David Winch of Accounting Evidence:

    Courses Online

  • Michael Kaye, of Kaye Tesler & Co writes as follows: "One of the Regulations is that firms must train their staff at pain of a criminal conviction carrying a sentence of up to two years plus an unlimited fine. Staff training can not only be expensive but additionally is disruptive to the office as staff obviously cannot work while the trainer is present. Further problems can arise if staff were absent when the trainer called or indeed if new staff joined after the office training had been completed. Together with Jonathan Fisher QC, I have designed and published on the Internet a web based training system. Each staff member can undertake the training course at his or her convenience. The price is £35 plus VAT per head with discounts for 10 or more staff members. There is a free demo on the web site which actually is the first training session. In addition there is a free money laundering news page on the site (take the "News" menu item on the left) with frequent updates.

  • Socrates Training provides CPD accredited training on audio CDs and cassettes. They offer a pack on money laundering, comprising a compliance manual, forms and precedents, and up to 2 hours training on CDs and tapes. Launched in January 2004, the pack offers firms all they need to comply with the new money laundering regulations, in force 1 March 2004. The people behind Socrates are former Director of the London College of Law, Bernard George, and Frances Owen, former head of Business Law at the London College of Law.

    Software and Consultancy Services

  • Lawfusion and MLDirect from Select Legal provides one-click electronic identity confirmation as an integral part of the firm's file set-up procedure. The software can be provided either as part of Select's overall practice management system or as a component to upgrade any Microsoft Windows system. The service requires an "always on" internet connection and an annual subscription.

  • Solicitors Case Management Systems (SCAMS) was designed by former solicitor Terry Frost. One of the modules is comprehensive risk management software which includes many anti-money laundering features for High Street practitioners, to help comply with the new Regulations & the Law Society's updated guidance. Features include:
    * A helpful Client Identification Form to complete upon opening a matter file
    * Timely warnings whenever money is paid into/out of client account
    * A comprehensive, yet uncomplicated Internal Report form
    * Quick & effective notification to your Money Laundering Reporting Officer
    * Warnings to users during the SOCA notice period & moratorium period
    * Automatic generation of the SOCA Disclosure Report Form
    * Automatic storage of documents within a separate money laundering file
    * Easy access to concise training notes.

  • MLRO Support Ltd. offers support to MLROs, particularly those in professional firms. The key resource is that members may email up to 4 questions each month for individual emailed reply within 24 hours. Membership costs 30 per month. The company is run by David Winch, a forensic accountant and expert on this topic. He is the author (jointly with Janet Bazley of Lincoln's Inn) of "Money Laundering for Lawyers: the new requirements and their practical implications" published by Butterworths. David Winch also runs a company called Accounting Evidence Ltd consisting of forensic accountants specialising in crime and proceeds of crime, including restraint, confiscation and civil recovery proceedings under the Proceeds of Crime Act 2002 and earlier legislation.

  • AML Custodian Money Laundering Protection Software from Opsis Practice Management Solutions is a standalone software product for money laundering protection developed by software supplier OPSIS. It is simple to install and set up and is user friendly, with a simple "Getting Started Manual".
    Here is a snapshot of what it can do:
    * Staff training: Using Sentinel will ensure your staff are complying with all AML procedures and store their AML training records.
    * Verifying Client ID: Sentinel automatically prompts you for the correct form of client ID verification.
    * Record-Keeping: All ML information is stored in a central place and it comes with an integrated Xerox Scanner that allows you to efficiently store electronic copies of ID documents.
    * MLRO Reports: Sentinel produces reports of all clients verified/not verified, clients under suspicion, clients blacklisted etc.
    * Raising Suspicions: Sentinel allows any member of staff to generate a suspicion and alert the MLRO quickly and efficiently.
    * NCIS: Automatically produces the NCIS Disclosure Report Form.
    The software only costs £999.00 (+ VAT) for 5 concurrent users and an integrated Xerox scanner (no hidden extras). This is a fully compliant and effective money laundering system at a very sensible price.

  • Web4law are a specialist risk and quality consultancy that have recently succeeded in gaining the Law Society training contract for training in the new Lexcel scheme. The company has also prepared the recent revision to the Law Society's office procedures manual. The company's money laundering training consists of a two hour session for fee earners with a shorter equivalent for support staff. The training is accompanied by a CD PowerPoint programme for use in future induction meetings and for those who miss the session. A team of five presenters are available to deliver the course.

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