In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation also covers the concept of criminal property, the Spanish bullfighter exception, and the balance between confidentiality and reporting obligations.

Takeaways

• Verifying source of funds in transactional and non transactional matters.
• The role of the MLRO in anti-money laundering compliance.
• Learn about the concept of criminal property under POCA.
• Explore the Spanish bullfighter exception in legal contexts.
• Balance confidentiality with reporting obligations in legal practice.
• Identify the challenges of anti-money laundering compliance.
• Discuss the principle of fungibility in financial transactions.
• Examine the role of legal professional privilege in reporting.
• Highlight the need for ongoing training in compliance.

Spanish Bullfighter LSAG reference

https://www.sra.org.uk/globalassets/documents/solicitors/firm-based-authorisation/lsag-aml-guidance.pdf#=page193

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation also covers the concept of criminal property, the Spanish bullfighter exception, and the balance between confidentiality and reporting obligations.

Takeaways

• Verifying source of funds in transactional and non transactional matters.
• The role of the MLRO in anti-money laundering compliance.
• Learn about the concept of criminal property under POCA.
• Explore the Spanish bullfighter exception in legal contexts.
• Balance confidentiality with reporting obligations in legal practice.
• Identify the challenges of anti-money laundering compliance.
• Discuss the principle of fungibility in financial transactions.
• Examine the role of legal professional privilege in reporting.
• Highlight the need for ongoing training in compliance.

In this episode of The ANL Clinic, we dive into one of the most critical and often misunderstood areas of financial crime prevention: the difference between source of funds and source of wealth.

We explore a real Solicitor Disciplinary Tribunal case involving a politically exposed person, a £1.1 million transaction and a £1.9million transaction, and serious gaps in due diligence.

Key takeaways:

• Why distinguishing source of funds vs source of wealth matters
• The risks of relying on third-party assurances
• How compliance failures can lead to disciplinary action

SRA | Thematic review of source of funds and wealth compliance | Solicitors Regulation Authority