Under Regulation 18 of the Money Laundering and Terrorist Financing Regulations self-employed barristers and BSB entities that carry out work that falls within the scope of the Regulations must take appropriate steps to identify and assess the risks of money laundering and terrorist financing to which their practice or business is subject.
In carrying out the risk assessment, you must take into account factors that are set out in Regulation 18, which include the type of services that you are engaged in, the geographic areas in which you operate, the type of services you deliver and how you deliver them.
You must also take into account any information we make available to you. Under Regulation 17, we are required to identify and assess the money laundering and terrorist financing risks associated with the Bar. We will be publishing our assessment in due course. In the meantime, you can refer to the following resources which may assist you:
- Bar Council guidance
- National Risk Assessment
- SARs report
- FATF Risk-Based Approach Guidance for Legal Professionals
- FATF Risk-Based Approach Guidance for TCSPs
You must document the risk assessment and keep an up-to-date record in writing of the steps you have taken to identify the risks so that you can make it available to us upon request.
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