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AML lawyer [SRA] money laundering risks - vendor fraud through to human trafficking and modern slavery


A report by the Solicitors Regulation Authority (SRA) for its most recent board meeting has highlighted an increase in the number of Suspicious Activity Reports (SARs) filed by its members about potential money laundering.

As a result of SRA work, over the past year they reported 26 money laundering related SARs to the National Crime Agency involving more than £200 million in suspected criminal proceeds. The key themes of money laundering related activity have remained broadly unchanged since last year. These include money laundering linked to:

  1. Residential property conveyancing
  2. Fraud
  3. Tax evasion
  4. Bogus investment schemes
  5. Clients/funds from high-risk jurisdictions
  6. High-risk commodities (precious and scrap metals)
  7. Aborted property transactions
  8. Vo underlying legal service or purpose for the transaction
  9. Complex offshore company structures/trusts
  10. Human trafficking and modern slavery.

Money laundering linked to vendor fraud was identified as a critical theme in the SARs we reported.

  1. This is where homes are targeted by fraudsters and sold without the knowledge or consent of the true owners, with the elderly and vulnerable often the victims.

The report says these SARs, which cover the 12 months to October 2020, include some £200 million in suspected criminal proceeds reported by the SRA to the National Crime Agency to support law enforcement efforts to disrupt and prosecute offenders, protect the public and tackle financial crime.


But Gwilliam says the increase in SARs issued by her organisation are not down to an increase in criminal behaviour, but instead heightened awareness among solicitors about their money laundering responsibilities, and therefore greater alertness.

  • "We remain committed to ensuring that all SRA staff members are aware of money laundering and terrorist financing related risks and the obligations placed upon everyone to internally report their suspicions," she says.
  • "We continue to deliver a range of money laundering and terrorist financing training courses."

Read the report in full.


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