The Legal Sector Affinity Group’s updated guidance on the anti-money laundering regulations has been updated for 2025 and is now in force, replacing the guidance issued in March 2023 and the addendum issued in December 2023. For all SRA-regulated firms this now constitutes official guidance (see: SRA | Your AML obligations | Solicitors Regulation Authority).
The guidance includes a schedule of amendments from p. 221 onwards. Significant changes include:
- further guidance on source of funds checks in relation to third party contributions;
- further guidance on due diligence on corporate structures;
- the introduction of a new high-risk third country definition following the removal of schedule 3ZA from the Money Laundering Regulations;
- explanation of supply chain risk requiring an understanding of “the purpose of the service you are providing and who is ultimately benefiting from it”;
- corrections to percentages in determining corporate ownership and updated wording for beneficial owner shareholders to “more than 25%”;
- changes to the proceeds of crime regime under the Economic Crime and Corporate Transparency Act 2023 (ECCTA);
- new subsections incorporating changes brought about by the ECCTA; and
- information on the applicability of the Economic Crime Levy for firms with an annual turnover of more than £10.2 million.
