Last updated: July 2024

The FATF and European Union continually review jurisdictions and identifies those which have strategic deficiencies in their AML/CFT regimes. These are known as the FATF Grey List and high risk jurisdictions under the European Union.

Countries are added to the lists several times throughout the year. There are some jurisdictions which are on the EU list but not on the FATF list and vice versa. The UK has its own list under Section 49 of the Sanctions and Anti-Money Laundering Act, however the UK’s high risk jurisdictions point to the FATF grey list.

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VinciWorks was proud to host over 45 of the UK’s leading international law firms at our recent AML Core Group meeting. VinciWorks Business Development Director Tom Evans and Compliance Office Managing Director Andy Donovan shared best practice in the field of AML, and encouraged a dialogue between firms on how to best manage AML risk.

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Regulated firms will have to provide AML and sanctions data

UK regulated firms, the Solicitors Regulation Authority (SRA) is about to contact you with a new requirement for more of your money laundering and sanctions data.

What information are they looking for? Regulated firms will be asked provide information on:

  • work they carry out within scope of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
  • any contact or involvement they have with the sanctions regime and any persons who are designated under it
  • submission of suspicious activity reports to the National Crime Agency

Firms not involved with one or more of these regimes are still required to submit a nil return.

Take note: The window for responses opens in early August and closes in mid September.

Why are they collecting this data?

The SRA is required by its regulator, the Office for Professional Body Anti-Money Laundering Supervision to take a risk-based approach to supervision. It states that to supervise the legal sector effectively, it needs to have accurate data to see the distribution of risk across the legal profession. This in turn informs its programme of inspections and its guidance.

The SRA further states that collecting this information enables it to determine where the risks lie and how it can better allocate resources. Most importantly, the SRA notes, data needs to be up to date and relevant so its approach can evolve and adapt.

Significantly, the SRA adds that if it decides to publish this data, it will make sure that no one can be identified from what it publishes or shares.

Register now for our AML webinar – 31 July 2024

Join us in this free, one-hour webinar where we provide critical information on AML legislation, the many ways in which law firms can get caught up in money laundering and the implications if a firm doesn’t have effective AML workflows in place. Significantly, we will guide firms in how to implement best practice AML workflows to manage their money laundering risks so they can develop an effective AML programme and mitigate their risks of being exposed to financial crime. We’ll also discuss new SRA requirements on collecting AML data.

Wednesday 31 July, 12pm UK

Approximately £10 billion of illegal money is estimated to be laundered each year in the UK. And with most law firms exposed in so many ways to the risks of money laundering, the potential for a firm getting caught up in financial crime is easy, maybe easier than ever. It can happen at any point in the legal process – in the course of managing a client’s money or organising funds to create a client’s company or while helping a client buy property.

What’s worse, the repercussions for violating anti-money laundering (AML) regulations are steep, from large fines to civil or criminal charges to reputational damage. That’s all likely to get steeper with Labour planning on further crackdowns on dirty money.

A robust AML framework is the key. Join us in this free, one-hour webinar where we provide critical information on AML legislation, the many ways in which law firms can get caught up in money laundering and the implications if a firm doesn’t have effective AML workflows in place. Significantly, we will guide firms in how to implement best practice AML workflows to manage their money laundering risks so they can develop an effective AML programme and mitigate their risks of being exposed to financial crime. 

This webinar will feature:

  • A basic understanding of the AML regulations in the UK
  • Ways to assess your firm’s risks for money laundering
  • Relevant money laundering case studies – and what you can learn from these stories
  • How to implement AML best practice workflows
  • How to develop an AML programme that works

Register now

With its 20-point lead in opinion polls, Labour seems poised to win in the UK’s upcoming July 4th election. If indeed Labour form the next government, economic crime in general and anti-money laundering in particular are likely to form the backbone of initial legislation given the unending criticism of the UK’s role in the ‘global laundromat,’ which London was called by shadow foreign secretary David Lammy, though even the former Conservative justice secretary criticised the last government for not introducing this failure to prevent money laundering offence and for watering down the failure to prevent fraud offence.

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The SRA updated its sectoral risk assessment. Here’s what your firm needs to consider

Money laundering and the financing of terrorism are risks to most firms and the means by which criminals target law firms to commit these crimes are becoming increasingly sophisticated. Solicitors are forced to keep pace with the methods of financial crime – to adhere to regulations and to protect their clients and the public interest. Unsurprisingly, the Solicitors Regulation Authority (SRA) encourages firms to undertake regular risk assessments.

This past March, the SRA updated its sectoral risk assessment on anti-money laundering (AML) and terrorist financing. Law firms are required to take a risk-based approach, which means that they need to assess their risks and focus their resources on the areas or products that are most likely to be used in financial crime.

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The new act, which demonstrates a shift in the UK’s approach to economic crime and corporate governance, is in its first phase of enactment

The Economic Crime and Corporate Transparency Act (ECCTA) is a significant piece of UK legislation that aims to tackle economic crime and improve corporate transparency by strengthening the regulatory framework, increasing accountability and ensuring that companies operate in an open manner. 

“This is one of the most significant moments for Companies House in our long history,” stated Louise Smyth, Chief Executive and Registrar of Companies, referring to the ECCTA’s passing.

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The UK’s latest attempts at tackling dirty money, the Economic Crime and Corporate Transparency Act (ECCTA), passed by the Conservative government in late 2023, did not come without criticism from Labour. Shadow Minister for Investment and Small Business Rushanara Ali attacked the legislation as it went through the House of Commons as not going far enough to tackle Labour’s view that the UK has become a money laundering haven.

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In a stunning rebuttal to the global financial crime watchdog the FATF, the European Parliament voted on Tuesday 23 April to keep the United Arab Emirates on the EU’s list of High Risk Third Countries. This will complicate due diligence efforts for regulated entities who may no longer be able to rely solely on the FATF grey list as the single source of truth for jurisdictions at high risk of financial crime. 

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The move comes as Australia seeks to implement stricter AML laws nationwide

In an effort to prevent money laundering, Queensland implemented legislation that limits cash gambling at the state’s casinos. The new law also involves identity verification and a code of conduct at casinos. The legislation comes as Tranche 2 anti-money laundering (AML) reforms are likely to soon come into force in Australia. 

Queensland attorney general Yvette D’Ath noted that casinos will be restricted to accepting a certain amount of cash from a person for gambling-related transactions in a 24-hour period. The cash limit will be set through regulation but is likely to be about $1,000. 

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