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Anti-Money Laundering Services for UK Regulated Law Firms

Alexander Christian assists regulated law firms with their AML obligations

Practical, Proportionate Support for Regulated Firms
Alexander Christian is a boutique firm, we support regulated law firms with Anti-Money Laundering (AML) obligations under the Money Laundering Regulations 2017— through tailored, discreet, and practical services. Whether you need a second set of eyes, a mock audit, or an independent Regulation 21 audit, we help you meet your obligations in confidence.

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

Alexander Christian - Anti-Money Laundering Audit Services
Alexander Christian - Anti-Money Laundering Compliance Services
Anti-Money Laundering Audits (AML) Audits

Let's help you find a solution

Solutions: Strengthen your AML Compliance

At Alexander Christian, our Mock AML Audits simulate real regulatory scrutiny, helping you identify strengths and address weaknesses before a Regulation 21 Audit. We also provide formal Regulation 21 Audits, File Reviews, and Staff Interviews to assess how well your AML framework is working in practice. If your concern is implementation, our services highlight where policies may not be followed on the ground. Our Focused AML Audits target specific issues, giving you clear insight and practical solutions. Whether you're preparing for review or want peace of mind, our audits help build a stronger, more effective AML compliance framework.

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

Alexander Christian - Here to help

Frequently Asked Questions

"A journey of a thousand miles begins with a single step."

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.
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 AssessmentPolicies, 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 PhraseWhat it means Why it matters
 AML Anti-Money LaunderingAnti-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.
 CDDClient/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:

  • The Nature and Purpose of the Business Relationship: What is the client's objective, and how does the engagement align with their known profile?

  • Geographic Risk: Are there connections to High-Risk Third Countries (HRTCs) or jurisdictions with elevated corruption levels?

  • Client Risk Factors: Is the client, or anyone associated with them, a Politically Exposed Person (PEP), or do they present other specific risk indicators?

  • Sanctions Compliance: Rigorous screening against all relevant sanctions lists.

  • Reputational Risk: Scrutiny of adverse media and other public information to identify potential illicit activity or reputational concerns.

  • Ongoing Monitoring: Regularly reviewing and updating client information and transaction behaviour to ensure consistency with initial assessment

 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:

  • Identifying and assessing risks related to terrorist financing.

  • Implementing robust controls to prevent legal services from being used to raise, move, or conceal funds intended for terrorism.

  • Conducting thorough due diligence on clients, beneficial owners, and transactions to identify potential links to terrorist financing.

  • Screening against sanctions lists to identify individuals or entities designated as terrorists or terrorist financiers.

  • Reporting suspicious activity (Suspicious Activity Reports - SARs) to the National Crime Agency (NCA) or relevant authorities when there are grounds to suspect terrorist financing.

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.

 EDDEnhanced 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:

  • Deeper understanding of the transaction's purpose and client's background.

  • Enhanced verification, especially for source of funds/wealth.

  • Increased, ongoing monitoring.

  • More extensive sanctions and adverse media screening.

  • Often requires senior management approval.

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:

  • Identify and understand their unique AML risks (clients, services, geographies, transactions and delivery channels).

  • Tailor their Policies, Controls, and Procedures (PCPs) accordingly.

  • Guide individual client/matter risk assessments.

  • Demonstrate compliance to regulators 

Without it, a firm's AML defence is incomplete and non-compliant. It's a living document requiring regular updates.

 KYCKnow Your Customer

KYC (Know Your Customer):

  • Focus: Primarily on initial client identification and verification. It's about establishing who your client is.

  • When: Usually performed at the very outset of a business relationship (client onboarding).

  • What it involves:
  • Collecting basic identifying information (name, address, date of birth for individuals; registration details, directors for companies).
  • Verifying this information using reliable, independent sources (e.g., passports, driving licenses, company house records).
  • Often includes an initial screening against sanctions lists and basic PEP checks.
  • Think of it as getting to know your client/ customer
 MLROMoney 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:

  • Receiving and assessing internal reports of suspicious activity from staff.

  • Determining whether a Suspicious Activity Report (SAR) should be made to the National Crime Agency (NCA).

  • Acting as the main point of contact for the NCA regarding AML/CTF matters.

  • Ensuring the firm's AML policies, controls, and procedures are effective and kept up to date.

References in MLR 2017 and LSAG 2025:

  • Money Laundering Regulations 2017 (MLRs): The requirement for a firm to appoint an MLRO (or an equivalent role, depending on the firm's structure and size) is primarily found in Regulation 21(1)(a), which mandates firms to establish policies, controls, and procedures, including "an individual nominated by the relevant person to be responsible for the relevant person's compliance with these Regulations." While not always explicitly named "MLRO" in the Regulation itself, this is the role's statutory basis.

  • Legal Sector Affinity Group (LSAG) Guidance 2025: The LSAG Guidance provides extensive detail on the MLRO's role and responsibilities. It elaborates on their independence, authority, reporting lines, training needs, and the specific duties related to internal and external suspicious activity reporting. The guidance consistently refers to the MLRO (Money Laundering Reporting Officer) as the key figure for AML compliance within a firm.

In essence, the MLRO is the designated "gatekeeper" and ultimate internal authority for a firm's AML/CTF compliance and reporting obligations.

 NCANational 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:

  • Investigating serious organised crime: This covers a wide range of activities such as human trafficking, drug trafficking, cybercrime, and economic crime.
  • Leading the fight against economic crime: A significant part of their work involves disrupting money laundering, bribery, and corruption, as these underpin much of organised crime.
  • Receiving and analysing Suspicious Activity Reports (SARs): The NCA houses the UK Financial Intelligence Unit (UKFIU), which is the central point for businesses (including legal firms) to report suspicious financial activity related to money laundering or terrorist financing. These SARs are vital intelligence for their investigations.
  • Working with international partners: Given the cross-border nature of serious crime, the NCA collaborates extensively with law enforcement agencies globally.
  • Providing intelligence and capabilities: They gather, store, process, and disseminate criminal intelligence, and offer specialist capabilities to support other police forces and agencies across the UK. 


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.

 PCPsPolicies, 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.

 SARsSuspicious 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:

  1. Information SAR: This is a standard report made to alert the NCA to known or suspected money laundering or terrorist financing. It doesn't seek a defence for a future action.

  2. Defence Against Money Laundering (DAML) SAR: Submitted when a firm suspects they might be dealing with criminal property and need the NCA's "appropriate consent" to proceed with a transaction or activity without committing a money laundering offence.

  3. Defence Against Terrorist Financing (DATF) SAR: Similar to a DAML, but specifically for situations where there's a suspicion of terrorist property or financing, and consent is sought to avoid committing a terrorist financing offence.

 Regulation 21 AuditIndependent 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

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Do not hesitate to contact us with any queries.

Alexander Christian

Harrow Business Centre

429-433 Pinner Road

North Harrow

Middlesex

Greater London
HA1 4HN

Phone : 020 4578 4684

www.alexanderchristian.co.uk