Anti-money laundering (AML) compliance remains a key priority for Scottish law firms, with risk assessments forming the foundation of a robust compliance framework in this area. Yet, as the Law Society of Scotland’s 2024 Anti-Money Laundering Supervisory Report highlights, many firms unfortunately continue to grapple with the implementation of robust, comprehensive risk assessment frameworks.
It states that themes identified through their Supervisory inspection regime continue to include:
- A lack of detail contained within Practice Wide Risk Assessments (PWRAs) which leads to limited effectiveness in terms of the application of a risk-based approach
- A lack of understanding regarding the importance of assessing and documenting risk at a client/matter level, including nature, background, and circumstances
Properly evaluating potential clients and their proposed instructions is crucial for law firms. Failing to do so can make them vulnerable not only to regulatory actions but also to significant reputational damage and financial penalties. Moreover, it exposes the firm to the risk of laundering proceeds from criminal activities, irrespective of the firm’s size, specialism, or expertise.
Simplifying risk assessments for law firms
Many firms struggle with fragmented compliance processes, often using multiple spreadsheets, paper-based records, or separate templates stored in different locations. This not only increases the administrative burden but also makes audits and reviews more challenging.
Amiqus has expanded its risk assessment functionality, providing Scottish law firms with everything they need to conduct thorough, well-documented risk assessments in one easy-to-use platform. Speak to the Amiqus team for more details.
A range of templates and supporting documents created by the Law Society of Scotland has been added to the platform to support firms with their risk assessments. This includes:
1. Practice-wide risk assessment template
A structured form designed by the Law Society of Scotland to help firms identify and evaluate money laundering and terrorist financing risks at a firm level. Completing a PWRA is a mandatory requirement of the MLRs 2017 and will likely form part of any supervisory inspection by the Society. While a practice does not need to use this template, it serves as a useful guide for practitioners and can also be used to compare and contrast with any other format your firm wishes to use.
2. Supporting guidance for risk assessments
The LSS risk assessment forms have been adapted to include reference to the LSS supporting guidance notes, covering both natural and non-natural persons. The template should be used in conjunction with the guidance notes so those completing the risk assessments have further regulatory-approved guidance straight to hand to aid them in completing each section of the risk assessment.
Additional templates and support we’ve introduced
In order to help ensure you have all relevant materials and records in one place – centrally and securely stored in the platform, we have introduced a number of additional templates and support materials, such as:
1. AML policies and procedures template
A template to document AML policy and related procedures to help partners and staff fulfil their responsibilities by providing a clear framework for their AML strategy, along with setting out the firm’s key principles and obligations.
2. Breach report template
A ready-to-use form for reporting material or systemic AML compliance breaches to the Law Society of Scotland AML team, helping firms stay on top of regulatory obligations. The firm’s MLRO simply completes the form and emails it to [email protected].
More information on these requirements can be found on the LSS AML FAQs webpage under the question “What Type of breaches Must I Report?”
3. LSAG AML guidance 2023
This is a fully comprehensive, 220-page AML compliance guide approved by HM Treasury for use by legal professionals. It is well-divided and has an indexed contents page for easy navigation. The guide adds colour to the underlying regulations and offers practical guidance on how to comply with your AML obligations.
Amiqus: your trusted compliance partner
Amiqus collaborates with the Law Society of Scotland on AML and Lawtech initiatives and participates in the LawScotTech project. Through this close partnership, Amiqus remains informed about AML regulations and continuously improves its product based on their guidance.
Our Director of AML and Economic Crime Risk, Graham MacKenzie, is the former Head of AML at the Law Society of Scotland, so we are well-placed to help you navigate the complexities of AML compliance.
Amiqus helps firms meet compliance with AML regulations and LSAG guidance by providing AML checks and sanctions screening solutions tailored to the needs of Scottish legal practices.
By bringing together risk assessments, due diligence checks, compliance documentation, and more in one platform, Amiqus makes it easier for firms to fulfil their AML obligations while improving efficiency and reducing risk.
Whether you’re looking to enhance your firm’s risk assessment process or streamline your overall AML compliance, Amiqus provides the trusted tools and guidance you need.
Ready to access our new and improved risk assessment offering, along with expert advice and support? See the Amiqus platform in action over a quick call—book your personalised demo.
