Law Firms / Solicitors

UK law firms are subject to the Money Laundering Regulations and are currently supervised for AML purposes by a professional body supervisor within the legal sector. Firms are required to be registered with an appropriate professional supervising body and to comply with sector-specific guidance, regulatory rules and supervisory expectations.

This position is changing. The UK Government has confirmed reforms that will see AML supervision for professional services firms, including law firms, transition to the Financial Conduct Authority. Under the new regime, law firms will be required to register directly with the FCA for AML supervision.

This will involve firms:

• Obtaining FCA user credentials for the FCA’s online systems
• Registering the business for AML supervision
• Registering relevant senior individuals, including those responsible for AML oversight

Firms will be required to go through a more structured and stringent registration process, designed to ensure they are operating to strict AML standards and are able to evidence effective governance, controls and oversight.

Law firms should therefore be preparing not only to meet current supervisory expectations, but also to transition smoothly into the incoming FCA-led AML supervisory regime.

The FCA expects law firms and solicitors to demonstrate that their AML frameworks are not only documented, but effective, proportionate and operating in practice.

In particular, the FCA expects law firms to be able to evidence:

• A firm-wide risk assessment that accurately reflects the nature, scale and complexity of the firm’s legal services and client base
• AML policies, controls and procedures that are tailored to the firm and actively used by partners and staff
• Effective customer due diligence and enhanced due diligence, applied consistently and supported by clear records
• Strong governance and oversight, including clear accountability at senior management and MLRO level
• Appropriate ongoing monitoring and review of client relationships and matters
• Training that is role-appropriate, up to date and properly documented
• Clear audit trails and evidence demonstrating how AML decisions are made, challenged and escalated

The FCA places particular emphasis on governance, accountability and evidence. Firms that are unable to clearly demonstrate how AML controls operate in practice — even where policies exist — are likely to face supervisory challenge.

Law firms should therefore ensure their AML arrangements are robust today and capable of meeting the higher, more consistent standards expected under FCA supervision.

The AML Practice offers comprehensive support to Law Firms / Solicitors, meeting all their AML compliance needs, including: 

AML Gap Analysis

We begin by reviewing your existing AML framework against current UK legal sector expectations. This includes your risk assessment, policies, procedures, governance arrangements, training records and file-level controls.

You receive a clear written gap analysis highlighting:

• Areas of regulatory risk
• Practical weaknesses in implementation 
• Priority remediation actions
• Evidence gaps that may cause supervisory concern
   

AML Audits & Independent Reviews

We carry out structured AML audits and independent reviews designed for law firms, focusing on both design and operational effectiveness.

Our audits assess:

• Whether controls are appropriate for your risk profile
• Whether they are consistently applied across the firm
• Whether they are adequately documented and evidenced
   

Audit outputs are clear, proportionate and suitable for internal governance or regulatory engagement.

FCA Supervision Preparation & Application Support

As AML supervision transitions to the FCA, law firms will need to demonstrate stronger governance, clearer accountability and more consistent evidence.

We support firms by:

• Preparing AML frameworks aligned to FCA supervisory expectations
• Reviewing governance, oversight and reporting structures
• Supporting FCA engagement, onboarding and supervisory readiness
• Ensuring documentation and controls are regulator-ready
   

Our focus is on ensuring your firm is not caught out by the shift in supervisory approach.

Ongoing AML Support & Retainers

For firms that want continued assurance, we provide ongoing AML support on a retainer basis. This includes:

• On-hand ad-hoc AML advice for partners, MLROs and compliance leads
• Support with higher-risk matters, EDD questions and escalation decisions
• Periodic reviews of AML documentation and risk assessments
• Updates on regulatory and supervisory developments affecting law firms
   

This model provides reassurance without the cost of maintaining a full in-house compliance function.

Annual AML Compliance Attestation

We support law firms with annual AML compliance attestations, providing structured assurance that:

• AML controls remain appropriate and effective
• Risk assessments have been reviewed and updated
• Policies and procedures remain aligned to current guidance
• Training obligations have been met
   

This creates a clear annual compliance record for governance, audit and supervisory purposes.

AML Training for Lawyers & Staff

We deliver practical AML training tailored to legal practices, covering:

• Firm-specific risks and typologies
• Real-world legal sector scenarios
• CDD, EDD and source of funds expectations
• Escalation, SAR decision-making and MLRO responsibilities
   

Training can be delivered to partners, fee-earners, support staff and senior management, with attendance and completion fully documented.

Our Approach

We work with law firms in a way that is:

• Practical and proportionate
• Focused on evidence, not just documentation
• Aligned to both current legal sector guidance and future FCA expectations
• Designed to stand up to supervisory scrutiny
• No generic templates. No unnecessary complexity.