Information on money laundering regulations and how these affect lawyers, including training resources
and consultancy services available on this topic, maintained by Delia Venables.
The Law Society
has a section on this topic with practice notes and advice and the latest news.
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.
KYC360° is an online anti-money laundering community for AML professionals
to share their experiences and to provide tools and
resources that help them in their roles. Based in Jersey, the group has over 3,000 members in over 109 countries.
Members come from financial services and also include regulators and financial intelligence units, prosecutors,
trusts, banks, insurance firms, hedge funds, lawyers and accountants. The site includes articles, hot topics,
news, videos and two free products. One of these is called RiskScreen which scours OFAC and HMT sanctions
lists and then searches the internet using pre-defined keyterms looking for political and criminal connections.
Users can select name manipulation which will add in known name variations and also look for a name in reverse order
(this helps pin down entities who may appear on an Interpol list for example). Users can mark results as they
browse and hold a record of the results at the end of their searches.
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 useful links relating to money laundering regulations
Socrates Training provides CPD
accredited anti-money laundering training in video format. They also give subscribers a precedent
compliance manual, a self-assessment quiz and guidance on various difficult issues, plus an
updating service. Launched in January 2004, Socrates offers firms all they
need to comply with the latest regulations and practice. The service is
run by the former Director of the London College of Law, Bernard George.
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.
