This past Thursday, July 10, Vinciworks held another in its successful series of AML core group meetings hosted and facilitated by the VinciWorks and Compliance Office team. These meetings have served to create a tight and powerful community of AML professionals in the world’s leading law firms. They have also become an opportunity for these professionals to come together to share ideas and best practices. AML Core Group meetings are by invitation only. Reach out here if you are interested in participating.

Best practices forum

VinciWorks’ Business Development Director Tom Evans led a rousing best practice AML forum in which participants raised their most burning AML questions and issues to the group, who provided engaging and valuable responses.

Among the issues discussed were how firms approach audits . Specifically, the question involved whether firms have a rolling multi-year plan or go for all the reporting, remediation activity and improvements on an annual basis. Next, the question of practical steps firms are taking to verify Source of Wealth in high-risk and complex cases was discussed. 

Another participant wanted to know what enhanced due diligence looks like for firms. And, of course, a discussion was held on the Treasury’s recent announcement that it plans to introduce ‘clearer and more proportionate’ MLRs before the end of the year, after a government paper acknowledged AML checks are seen as a ‘major burden’ to law firms. Tom asked the group, what areas of AML controls or ‘proportionality’ do you expect to be addressed or relaxed? The answers were varied, fascinating and provided real value.

Onboarding corporate clients

This session of the AML Core group was excited to have Ray Blake, host of the well-known podcast, the Dark Money Files, give a session on the law and practice of onboarding corporate clients. In an interactive and dynamic session, Ray covered the legal obligation and then how just meeting the law can sometimes not be enough. He explored scenarios that could trip people up like the “borrowed address,” how they worked and, significantly, how you can avoid getting caught up in that kind of case. 

A lively question and answer session was held at the end. 

Breakout session: Failure to prevent fraud

Our breakout session was on failure to prevent fraud, which is coming into force soon. Led by Jen Dunlop, the managing director of Compliance Office, participants were asked the relevant and important question: What is your firm doing to prepare for it?

Jen gave participants questions to consider, such as will this offence apply to your firm and if so, what is your approach? And if not, will your firm still change its policies and procedures to prepare? Jen wanted to know if staff is being trained and what are firms’ plans for monitoring compliance.

Firms had a variety of discussions about their plans, which included combining this new offence into existing risk assessments. Some firms plan on undertaking Vinciworks training soon while others plan to conduct internal training led by their MLCO. 

Some of the firms  not currently in scope are still putting in place policies and training as best practice. They are opting to complete a separate risk assessment for easier management. Many of the firms noted that the process of conducting the assessments led them to create an anti-fraud policy.  

Larger firms in general noted that there was global buy in to the process but smaller and medium sized firms, which are not yet in scope, noted that they are struggling to get managers more engaged. “Their attitude is, we’ll get there when we get there,” noted one of the participants. Adding to the challenge is the fact that currently there is little guidance from the Law Society and the SRA. 

In terms of data collection and reporting, firms indicated that they are reviewing broader data reporting processes, acknowledging current data isn’t sufficient for proper risk assessment, and putting in place new systems to support risk assessment efforts. A number of firms expect to fall within scope in the future.

If you are interested in joining our next AML Core Group complete this short form and we’ll be in touch.

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