This year’s AML annual certificate is shorter. That’s good news – but it’s also worth pausing before you rush through it.
The Law Society of Scotland’s Anti Money Laundering (AML) certificate portal opened on 18 May 2026 and closes on 26 June 2026. Every Scottish firm in scope of the Money Laundering Regulations has to submit one, and the Money Laundering Reporting Officer (MLRO) is the only person who can press the button.
A lighter form, not a lighter obligation
The certificate has been scaled back this year. It’s now centered on self-certification against the Legal Sector Affinity Group (LSAG) Key Compliance Principles – the fundamentals that underpin any solid Anti-Money Laundering (AML) framework – alongside basic information about your practice and risk profile.
For firms working in an increasingly demanding environment, that reduction in scope is a genuine relief. But completing the certificate will still require care and diligence.
The principles matter
The LSAG Key Compliance Principles are the structure on which robust AML policies, controls, and procedures are built. Working through them gives you a clear picture of where your practice stands – and where it might need attention.
Think of this year’s certificate as a useful moment to step back and review what you have in place. Is it still proportionate to your risk profile? Does it reflect how your practice actually operates?
Accuracy works in your favour
Self-certification only works if the answers are accurate. The Society may sample responses, and could test what you’ve submitted as part of a future supervisory inspection.
If there are areas where your practice has work to do, the best approach is to say so clearly and explain how you intend to address them. Firms that demonstrate self-awareness and a credible plan to improve are in a much stronger position than those that can’t evidence the statements they have made on the certificate.
Use the open text boxes. They give you space to provide all the important context.
Keep the bigger picture in mind
Some of the questions that featured in previous certificates may also be reimposed next time around, or in future supervisory data return exercises. The broader data and information they generate is also important for maintaining your Practice-Wide Risk Assessment, which your firm is required to have under Regulation 18 of the Money Laundering Regulations 2017.
It’s worthwhile taking the time, and using this year’s certificate as a basis for reviewing and improving your practice’s AML controls, rather than viewing it as something to tick off and get off your desk
Amiqus helps law firms build compliance processes that hold up under scrutiny. If you’d like to talk through your current arrangements, we’re here.
Specialist AML Consultancy
Chat with Graham MacKenzie, Director of AML and Economic Crime Risk at Amiqus. Contact Graham here
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