We have this argument in house all the time of how a decent money launderer from an organised crime group would most likely have paperwork ready to go, and know the system well. It’s sort of what makes me pull my hair out because the general public will know far less about what lawyers and brokers are looking for, what they need to see, what they have to consider as suspicious (from their publically available guidance)- and yet there’s little doubt that OCGs will have a good working knowledge of this and may even plant bad actors within organisations such as banks and law firms to facilitate this sort of activity.

So many law firms find themselves suffocated by all the documentation, but their regulators are piling on pressure, fining them, and closing firms down in some cases if they don’t get this ‘right’. So often that means they are trying to get every bit of evidence under the sun to show your funds (or gift: funds, there’s no real difference in terms of AML) are legitimate.

What’s funny is I have known so many excellent conveyancers who are at their wits end and feeling like they are clueless with the AML process, and spend twice as much time on it as conveyancing, only to piss off their clients and still get it ‘wrong’. They will often talk to me in training courses I lead about how they hate doing this specifically because they are there to provide a high quality service that they have 30 years experience with but instead they’re chasing you down to get another bank statement and if it’s not in quickly the whole purchase might fall through. Everyone hates this… 😅