Key Documents they request
Key insights regarding AML Inspections
The Law Society of Scotland
The Law Society of Scotland is the regulator for Scottish Lawyers.
They are also the Anti-Money Laundering regulator body for Scottish Lawyers.
The have a proactive approach to the dissemination of information having produced information and templates.
In January 2025 they provided information about their AML inspection process.
What follow are some Key Takeaways. The source material is stated below, and you should read this information directly.
Key Takeaways
The publication provides a guide on how to prepare for an Anti-Money Laundering Inspection
How you are to send documentation
- Documents should be submitted via the Law Society's secure portal facility or egress encryption.
- Files should be clearly labelled (e.g., "Risk Assessment – Client Name", "Passport – Client Name").
- When providing information on specific matters, only relevant information should be included, avoiding details of other matters or non-AML related documents.
- A brief summary file note of key client details and a matter description can be helpful in minimising further enquiries.
Key Documents
They set out the key documents that they look for:
In appendices 1&2 they set out a specific list of documentation the AML team will look for during Full Assurance Inspections:
Part 1 (Practice-wide documentation):
- Practice-wide Risk Assessment
- AML policy and related controls and procedures
- Client/matter risk assessment templates and forms
- ID&V/CDD templates & forms
- High Risk/Politically Exposed Persons (PEP) registers
- Suspicious activity report (SAR) reporting forms/templates
- AML training materials and records
- Practice's partnership, management, and employee structure
- MLRO reports/Risk Management Committee minutes
- Independent audit function procedures, findings, and results
- Details of AML Electronic Verification Systems used
- Details of sanctions/PEPs/adverse media systems used
- Data protection and record-keeping policies and procedures
- Evidence of board (or equivalent) approval and communication of policies, controls, and procedures.
- Evidence of board (or equivalent) approval of the practice-wide risk assessment.
- Evidence that the board (or equivalent) receives periodic reports from the MLRO.
- Evidence that AML compliance is a standard agenda item at board meetings (or equivalent).
Part 2 (Client/matter specific documentation):
- Terms of business/letter of engagement
- All AML risk assessments conducted on the client/matter
- Identification and verification documentation for all relevant individuals and corporate bodies
- Ownership structures (where applicable) and registers evidencing management and control
- Evidence of source of funds/wealth checks
- Evidence of screening (PEP status, sanctions, adverse media)
- Other due diligence materials (ongoing monitoring, reliance, etc.)
- Internal and external emails relating to AML requests and discussions
- Proof of property acquisition (if applicable)
The Law Society of Scotland's - Guide to AM Inspections