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Anti-Money Laundering Services for UK Regulated Law Firms
Alexander Christian assists regulated law firms with their AML obligations
Why does AML Compliance Matter?
If you're in-scope under the Money Laundering Regulations 2017, having a robust AML and Counter-Terrorist Financing framework isn’t optional — it's an requirement. Weaknesses in your AML setup can result in serious reputational and regulatory consequences, including public sanctions and fines.
Need AML assistance? Call us on 020 4578 4684
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Tailored AML Solutions for Regulated Law Firms
Anti-Money Laundering Audits (AML) Audits
Let's help you find a solution
Solutions: Strengthen your AML Compliance
Tailored Solutions for You
At Alexander Christian, our AML review services are tailored, not one-size-fits-all. We design each service — from Mock AML Audits and Regulation 21 Audits to focused area audits, file reviews, and staff interviews — around the specific structure, risk profile, and needs of your firm. This means our insights are relevant, actionable, and practical. Whether you’re seeking assurance, preparing for regulatory engagement, or identifying implementation gaps, we focus on what matters most to your compliance. By aligning our services to your real-world risks, we help ensure your AML framework is effective, proportionate, and built for your firm — not just for the file.
Proactive Insights for Continuous AML Improvement
AML compliance isn’t a one-off task — it requires ongoing attention. At Alexander Christian, our services offer proactive insight to support continuous improvement. Mock AML Audits highlight potential weaknesses before regulators do. Regulation 21 Audits provide clear benchmarks for progress. Focused audits, in-depth file reviews, and staff interviews help you uncover implementation gaps and track effectiveness over time. Each service is designed to give you practical, forward-looking feedback, so your AML framework evolves with your firm’s risk profile and regulatory expectations. By embedding regular reviews and honest insight, we help you move from reactive fixes to sustained, confident AML compliance.
Tailored AML Solutions for Regulated Law Firms
Find out more about our AML Services
Alexander Christian offers flexible, short term KYC/AML analyst support during audits, onboarding surges, or staffing gaps. We work within your existing compliance framework, assisting with CDD, red flags, and audit prep—without compromising governance. Your firm retains oversight and responsibility. Book a no-pressure chat to learn more.
A Mock AML Audit helps regulated law firms proactively assess and improve their compliance before facing a Regulation 21 audit. Identify gaps, enhance controls, and boost team confidence. It’s a strategic step for Money Laundering Reporting Officers (MLROs), new compliance leads, or any law firm ready to strengthen its AML defences without the pressure.
Regulation 21(1)(c) requires firms to conduct independent AML audits, not as a formality, but as a vital control. Our audits uncover blind spots, offer sector-specific insight, and strengthen regulatory confidence. With tailored recommendations and ongoing support, Alexander Christian helps you meet obligations—and improve your AML framework.
File Reviews
AML File Reviews enable regulated law firms to have a glimpse of the implementation of their Policy, Controls and Procedures (PCPs), and Client Matter Risk Assessments (CMRAs). A second set of eyes, helps to prevent compliancy and excuses setting in.
Supporting your AML needs
AML Staff Interviews
AML Staff Interviews can help firms assess whether AML training is not only delivered—but truly understood and applied in practice.
Without staff confidently recognising red flags, understanding the client holistically, and accurately completing Client/Matter Risk Assessments, there is a significant risk of misrating the client’s risk level or failing to escalate concerns appropriately. Even with well-drafted policies and procedures, a lack of staff implementation can result in serious non-compliances within a regulated law firm’s AML framework.
Focused Audits
You may not need a full Regulation 21 AML audit or a comprehensive mock audit. Instead, you might prefer to focus on a specific area of your AML framework. We offer bespoke reviews tailored to your priorities—allowing you to target resources where they’re needed most and strengthen key aspects of your compliance programme.
Your AML Firm-Wide Risk Assessment (FWRA) and your Policies, Controls, and Procedures (PCPs) are the foundation of your regulated firm’s AML framework. They are often the first reference point for staff seeking guidance on compliance expectations.
However, many firms rely on generic templates—making only minimal changes such as inserting their firm’s name—without tailoring the content to reflect their specific services, structure, or risk profile. As a result, these documents often fail to accurately capture the firm’s unique AML risks and operational realities.
If you’re not ready for a full audit but want to focus on strengthening your documentation, we can help. While we don’t draft your documents for you, we offer independent reviews of your existing documentation and provide constructive, practical feedback on how it can be improved to better reflect your firm’s risk and regulatory obligations.
Remediation
Your regulator may expect independent file reviews to assess key elements such as Source of Funds (SoF), Source of Wealth (SoW), and Client/Matter Risk Assessments (CMRAs). We can support you by carrying out these time-consuming reviews—offering the independence and objectivity that regulators often require.
Tailored AML Solutions for Regulated Law Firms

1. Do we really need an AML audit? We already have policies?
Yes — if you're in-scope under the Money Laundering Regulations, an independent audit may be required.
Regulation 21(1)(c) states that, where appropriate to your size and nature, you must conduct an independent audit to examine the effectiveness of your AML policies, controls, and procedures. This isn’t a paper exercise — it’s a key part of demonstrating oversight and good governance.
2. What’s the difference between a Regulation 21 Audit and a Mock Audit?
A Regulation 21 Audit is a formal independent audit required by law; a Mock Audit is a preparatory review.
A Mock Audit is a proactive check to assess your readiness and highlight areas of concern. A Regulation 21 Audit is a formal, documented independent audit that reviews the effectiveness of your AML framework, in line with legal requirements.
3. What if we just want help reviewing our AML documents?
That’s fine — we offer standalone AML documentation reviews.
If you're not ready for a full audit, we can review your Firm-Wide Risk Assessment, Policies, Controls, and Procedures (PCPs) or other AML documents, and provide independent feedback. It’s a great way to get assurance without the pressure of a full audit.
4. We don’t have time for a full review. Can you just look at a few files?
Yes — we offer focused AML file reviews.
We can review a sample of your client files to assess the quality of due diligence, risk assessments, and ongoing monitoring. This helps spot implementation issues or inconsistencies — and supports remediation before a regulatory review.
5. Will Alexander Christian take over our compliance work?
No — your firm stays in control. We support, not replace.
For services like temporary KYC analyst support, we work within your existing framework. Your firm provides access, supervision, and tools — we provide help for due diligence checks, file reviews, or audit prep.
6. Will this be shared with the regulator?
No — our services are confidential.
We don’t report findings to your regulator. Everything we do is strictly confidential and designed to help you address risks before they become regulatory problems.
7. What if our staff are nervous about being interviewed?
Our AML staff interviews are non-judgmental and constructive.
They’re designed to assess how well training and procedures are being understood and applied in practice. We’ll help you identify gaps and improve confidence — not blame or criticise staff.
8. Do you offer fixed-fee services?
Yes — many of our services are fixed-fee and scoped in advance.
We believe in clear, upfront pricing. After a quick conversation, we’ll give you a fixed quote based on the size and scope of the work. No hidden costs or open-ended fees.
Tailored AML Solutions for Regulated Law Firms
A Glossary of Anti-Money Laundering Acronyms
Acronym or Phrase | What it means | Why it matters |
AML | Anti-Money Laundering | Anti-Money Laundering (AML) in the legal sector refers to the comprehensive framework of laws, regulations, and internal procedures designed to prevent, detect, and report attempts by criminals to disguise the illicit origins of funds (proceeds of crime) or finance terrorism. For law firms, this involves proactive measures to safeguard against being exploited for financial crime. |
CDD | Client/Customer Due Diligence | Client Due Diligence (CDD) for legal firms is a multifaceted and continuous process designed to mitigate money laundering and terrorist financing risks. While client identification and verification are fundamental components, effective CDD goes much further, demanding a thorough understanding of:
|
CTF | Counter Terrorism Financing | Counter Terrorism Financing (CTF) refers to the efforts, laws, regulations, and procedures designed to prevent, detect, and disrupt the flow of funds and financial support to individuals, groups, and entities involved in terrorist activities. In the legal sector, CTF involves:
CTF is often intertwined with Anti-Money Laundering (AML) efforts, as both aim to combat illicit financial flows, even though the source of funds in terrorist financing can sometimes be legitimate. The goal of CTF is to deprive terrorists of the financial resources necessary to plan, train for, and execute their acts. |
EDD | Enhanced Due Diligence | In the legal sector, Enhanced Due Diligence (EDD) is a more rigorous level of client scrutiny applied when a client, transaction, or relationship presents a higher risk of money laundering or terrorist financing. It goes beyond standard checks to involve:
EDD is crucial for situations like dealing with High-Risk Third Countries (HRTCs), Politically Exposed Persons (PEPs), or complex, non-face-to-face transactions. It ensures robust defence against financial crime. |
FWRA or PWRA | Firm Wide Risk Assessment or Practice Wide Risk Assessment | The Firm-Wide Risk Assessment (FWRA) is foundational for AML compliance in the legal sector. It's a legal requirement (Regulation 18, MLRs 2017) that helps firms:
Without it, a firm's AML defence is incomplete and non-compliant. It's a living document requiring regular updates. |
KYC | Know Your Customer | KYC (Know Your Customer):
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MLRO | Money Laundering Reporting Officer | The Money Laundering Reporting Officer (MLRO) is a senior individual within a legal firm (or other regulated entity) responsible for overseeing the firm's compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. Their primary duties include:
References in MLR 2017 and LSAG 2025:
In essence, the MLRO is the designated "gatekeeper" and ultimate internal authority for a firm's AML/CTF compliance and reporting obligations. |
NCA | National Crime Agency | The National Crime Agency (NCA) is the UK's lead law enforcement agency for tackling serious and organised crime. Think of it as the UK's equivalent to the FBI, focusing on high-level criminal threats that cross regional, national, and international borders. Key responsibilities of the NCA include:
In essence, the NCA plays a crucial role in safeguarding the UK from the most serious criminal threats, with a particular focus on disrupting the financial flows that enable these illicit activities. |
PCPs | Policies, Controls, and Procedures | Policies, Controls, and Procedures (PCPs) are vital for AML in the legal sector because they are legally required (MLR 2017, Regulation 19) and translate a firm's identified money laundering risks into clear, actionable steps. PCPs ensure consistent AML practices, guide staff on their duties (e.g., CDD, reporting suspicious activity), and demonstrate to regulators (like the SRA) that the firm has a robust, practical system to prevent financial crime. They are the operational blueprint for AML compliance. |
SARs | Suspicious Activity Report | A Suspicious Activity Report (SAR) is a confidential disclosure made to the National Crime Agency (NCA) when a regulated professional knows, suspects, or has reasonable grounds to suspect money laundering or terrorist financing. There are three main types of SARs:
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Regulation 21 Audit | Independent AML Audit under Regulation 21(1)(c) | An Independent AML Audit under Regulation 21(1)(c) of the Money Laundering Regulations 2017 (MLR 2017) is a mandatory function (for most firms, dependent on size and nature of business) designed to objectively assess and evaluate the adequacy and effectiveness of a legal firm's entire Anti-Money Laundering (AML) policies, controls, and procedures. Crucially, "independent" means the audit cannot be carried out by those responsible for the day-to-day AML function, such as the Money Laundering Reporting Officer (MLRO) or Money Laundering Compliance Officer (MLCO), to ensure impartiality and avoid "marking their own homework." Its purpose is to identify weaknesses, make recommendations for improvement, and monitor compliance with those recommendations. |
Disclaimer: This page does not contain legal or regulatory advice and it is not intended that it is construed as such - see our disclaimer page
Tailored AML Solutions for Regulated Law Firms
Accreditations and Memberships

Law Society of England & Wales

International Compliance Association

ACAMs
Association of Certified Anti-Money Laundering Specialists

International Mediation Institute

Civil and Commercial Mediation

Interpersonal Mediation

Workplace Mediator
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Alexander Christian
Harrow Business Centre
429-433 Pinner Road
North Harrow
Middlesex
Greater London
HA1 4HN
Phone : 020 4578 4684
www.alexanderchristian.co.uk