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.