Anti-Money Laundering (AML)
Welcome to the Law Society AML online hub.
From here, you will find a wide range of guidance and support tools to assist solicitors and non-solicitors working in legal firms with navigating their AML-compliance obligations.
At a glance
- Are you using the Law Society’s key AML materials? [hyperlink to relevant section below once content has been imported]
- Have you completed the core free AML training on LegalEdTalks? [hyperlink to relevant section below once content has been imported]
- Are you familiar with the money laundering risks to the legal sector?
- Have you evaluated your firm’s vulnerability to being used to launder money?
- Have you put risk-appropriate AML policies, controls and procedures in place?
- Are you documenting your customer / matter risk assessments?
- Do you risk assess for money laundering BEFORE agreeing to act and gathering CDD?
- Do you engage with the due diligence as it comes in?
- Are you up-to-date with the latest developments?
- Have you adopted the traffic lighting red flags approach?
- Computerise your accounts if you are relying on manual accounts
- Review your dormant balances at least every six months
- Review your balancing statements every three months
- Make sure your section 150 precedents are up to date and that all bills are compliant with the Legal Services Regulation Act 2015
- Ensure that client account payment can only be authorised by a partner or principal
- Confirm that your AML procedures are up-to-date and properly recorded:
- Policies Controls Procedures need to be documented
- Business Risk Assessment need to be documented
- Evidence of Training of Staff need to be documented
- Client Risk Assessment needs to be documented on each file
- Make sure your accounts (and your files) are backed up off-site
- Maintain a register of undertakings (Regulation 38)
- Get a case management system
- Contact the Law Society if you are having difficulty
(This list is non-exhaustive and does not represent a complete summary of AML legislation and the Solicitors Accounts Regulations. For further guidance, please see below and the Society’s page on the Solicitors Accounts Regulations [bring user to new SAR content, once live])
If further assistance is required, please contact the Law Society’s AML helpline, email: aml@lawsociety.ie.
The AML helpline assists solicitors with best practice guidance. The legislation requires solicitors to make subjective decisions about, for example, the adequacy of CDD material in specific scenarios, whether a ML/TF risk arises on a case-by-case basis, or whether the reporting obligation arises in specific circumstances. Accordingly, the helpline cannot confirm the adequacy of AML documentation / approach to be taken in specific circumstances. The helpline cannot provide legal advice.