The AML / CTF Regulations impose on legal professionals statutory Client Due Diligence (CDD) and Record Keeping obligations. Legal practitioners are required to: 

  • verify the identity of new clients by obtaining information on those clients before accepting instructions
  • verify the identity of individual beneficial owners of clients
  • conduct enhanced due diligence in certain higher risk situations
  • conduct ongoing monitoring of clients and their activities
  • keep records of the above.

Practice Direction P imposes similar obligations on solicitors, foreign lawyers, and member firms regarding combating money laundering and terrorist financing. These requirements include policies and procedures regarding:

  • client identification and verification
  • client due diligence (including enhanced and simplified client due diligence)
  • timing for conducting client due diligence
  • record keeping
  • staff awareness and training.