AML and sanctions activities

Throughout 2023, as part of the development of the Law Society’s five-year strategy, the anti-money-laundering (AML) and sanctions activities were reviewed to ensure that both the Law Society and solicitors can continue to meet national and international standards and respond to the ever-changing external environment. The relevant strategic priority for AML is within the goal of promoting effective regulation.

The Ukrainian flag at Blackhall Place

The Law Society protects and supports the public interest and the solicitors’ profession by ensuring effective regulation. Its role as a regulator is understood and valued as central to sustaining trust in the solicitors’ profession and contributing to the Irish legal system, economy, and society.

In order to protect and support the public interest and the solicitors’ profession, the strategy visualises the Law Society:

  • leading best practice in the implementation of AML measures by liaising with key stakeholders to ensure appropriate and clearly understood legal frameworks and associated responsibilities for AML, and

  • establishing feasibility and resourcing requirements for a dedicated AML business unit.

As a first step in establishing this unit and leading best practice in AML measures, the Law Society’s AML policy and regulatory activities were consolidated into the Regulation Department in January 2024.

Outreach

The Law Society remains strongly focused on the provision of extensive AML and sanctions outreach initiatives to solicitors, while also increasing awareness and understanding of existing and emerging money-laundering and terrorist-financing (ML/TF) risk to the legal sector.

Outreach, guidance, training, and supervision activities reinforce compliance and prevention, while also responding to the evolving landscape. Guidance and resources are risk-based to ensure riskassessment and risk-appropriate CDD and policies at both client and business level.

Firms can ensure compliance by accessing the following key AML resources: Viewing the free 30-minute AML Update Session, availing of free on-demand AML training via the LegalEdTalks platform, viewing three infographics that communicate solicitor AML obligations visually, and adapting and adopting the four sample adaptable forms:

Through a dedicated AML Helpline, the Law Society provides tailored guidance in response to solicitor AML enquiries. The helpline provides realtime specific guidance by phone/ email.

The members’ area of the Law Society’s website hosts a dedicated AML resource hub, where solicitors can easily access and download all AML resources at any time.

Response to AML information remains strong, with 16,033 page views from over 5,000 users in the year to 31 May 2024. The latest training statistics indicate that, in 2023 alone, over 2,000 solicitors availed of free AML training on the Law Society’s LegalEdTalks platform. Over 1,200 have also now viewed the AML Information Session for sole practitioners and small firms available on YouTube since its launch in late 2021.

Sanctions

Responding to the introduction of sanctions on Russia over Ukraine, the Law Society launched a Sanctions Resource Hub on 8 March 2022 (see lawsociety.ie/sanctions). It contains information and helpful resources to assist solicitors ensure compliance with sanctions. The Hub is an agile resource that is continuously updated as new sanctions are enacted, and as guidance and insights emerge.

A key resource on the Hub is a five-step recommended approach to ensure compliance with sanctions, designed with sole practitioners and small/medium firms in mind.

Response to the Sanctions Resource Hub has been excellent, with 4,591 page views from over 2,000 users in the year to 31 May 2024.

AML compliance

Supervision of solicitor AML compliance continued to be delivered as part of the financial regulation of the profession. The Law Society’s regulation activities also satisfy EU requirements with regard to ‘fit and proper persons’. In 2023, 332 solicitor firms were inspected by the Law Society’s 11 investigating accountants for AML compliance. During 2023 and to the end of June 2024, the Law Society has issued directions that three solicitors’ practices undertake an external audit pursuant to regulation 5(10) of the Solicitors (Money Laundering and Terrorist Financing) Regulations 2020 and has referred three solicitors to the Legal Practitioners Disciplinary Tribunal solely on the basis of AML compliance failings noted during inspections.

National, EU and international

The Law Society continued its participation in the work of the AMLSC, Ireland’s national AML policy body hosted by the Department of Finance, as well as the Private Sector Consultative Forum. At EU level, contribution to AML and sanctions policy development through the Council of the Bars and Law Societies of Europe also continued.

Directly supporting the work of the EU Commission in ensuring lawyers across the EU can access AML training, the Law Society participated in the design and delivery of sector-specific training to over 1,000 EU lawyers in March 2024. Separately, a YouTube video of the event has since been viewed nearly 1,000 times. Given the overwhelming success of the training initiative, further training was provided in late May 2024 to a further 1,500 lawyers.