AML Training for Law Firms: Anti-Money Laundering and Sanctions Compliance
By Andrew Donovan ('Andy') | Former SRA Lawyer | Director Attuned Consulting
Published April 2026
With almost a third of SRA-inspected firms found non-compliant with anti-money laundering requirements in the most recent annual report, and the regulator more than doubling the number of firms it intends to audit, AML training for law firm staff has never mattered more.
We provide specialist anti-money laundering and sanctions training for law firms and in-house legal teams throughout England and Wales. Every session is delivered personally by Andy Donovan, a non-practising solicitor who spent seven years at the SRA and has trained thousands of solicitors and compliance professionals over more than fifteen years.
E-learning has a place in any firm's training programme - it is effective for onboarding and baseline awareness. But it cannot replicate working through a real scenario with a room full of fee earners, asking the difficult questions, and making sure the answers are grounded in your firm's actual procedures. That is where tailored face-to-face or online AML training can be helpful.
WHAT OUR AML TRAINING FOR LAW FIRMS COVERS
Our AML training sessions are built around a five-step framework that mirrors the practical reality of how fee earners encounter AML obligations in their day-to-day work. The content goes well beyond a summary of the regulations. We work through real scenarios, use genuine case studies drawn from SRA enforcement reports and decided cases, and spend significant time in small groups workshopping the problems that your team actually faces.
By the end of a session, participants will be able to explain the money laundering and terrorist financing offences most relevant to law firms, carry out appropriate identity checks for both individual and corporate clients, conduct sanctions and PEP screening, complete a client and matter risk assessment, apply enhanced due diligence where required, conduct source of funds and source of wealth enquiries, recognise the warning signs of money laundering, make a suspicious activity report correctly, avoid tipping off, understand the banking facility rule and the proper use of client account, and keep records that will satisfy SRA scrutiny.
The session also covers data protection obligations in the context of AML too - an area that is easy to overlook but is required by the Money Laundering Regulations 2017.
STEP 1 - CLIENT IDENTIFICATION AND VERIFICATION FOR LAW FIRMS
The foundation of any AML-compliant matter is knowing who you are dealing with and being able to prove it. We cover what is required to verify an individual client - name, date of birth and residential address - and what documents satisfy that requirement in practice, including the use of electronic verification tools and remote identification procedures for clients who cannot attend in person.
For corporate and entity clients, we work through the three-stage process: verifying corporate existence and constitution, obtaining executive identity checks, and identifying beneficial owners. This includes tracing beneficial ownership through complex group structures - one of the areas where fee earners most commonly make errors and one of the areas the SRA most commonly identifies as deficient.
A point that often surprises staff: the Money Laundering Regulations 2017 apply to specific regulated work, including conveyancing, company formation, trust work and certain financial transactions. They do not apply directly to litigation or most contentious work. But that does not mean identity checks can be skipped. Concealing criminal property under section 327 of POCA 2002 is an offence regardless of whether regulated work is involved. We make clear the distinction between what the Regulations require and what good risk management requires in every matter.
STEP 2 - SANCTIONS SCREENING, ADVERSE MEDIA AND POLITICALLY EXPOSED PERSONS
Screening is one of the areas where documentation most commonly lets firms down. The SRA expects to see evidence on the file that sanctions checks, adverse media searches and PEP checks were carried out - not just that a procedure exists.
We cover who must be screened as a minimum and when it is appropriate to go further, including screening funders, counterparties and professional advisers in higher-risk or cross-border matters. We work through the elevated risk indicators that should prompt closer attention: connections to higher-risk jurisdictions, links to sanctioned individuals, and transactions involving areas of known elevated risk such as luxury goods, freight, aviation or immigration work.
On politically exposed persons, we cover the definition in full - including the extension to immediate family members and known close associates - and what enhanced due diligence looks like in practice when a PEP is identified. Domestic UK PEPs are treated as lower risk than international ones but still trigger enhanced obligations. Senior management approval, enhanced source of wealth checks and heightened ongoing monitoring are all required.
STEP 3 - CLIENT AND MATTER RISK ASSESSMENTS
Completing a matter risk assessment is the responsibility of the fee earner handling the matter - not support staff, and not a formality to be completed after the fact. We work through what a proper risk assessment involves: recording reasoning, not just ticking boxes, and documenting the absence of risk factors as well as their presence.
We cover the triggers for enhanced due diligence, both the prescribed mandatory triggers under the Regulations - PEPs, connections to high-risk third countries, and unusual or complex transactions - and the broader factors that should prompt a more cautious approach. We spend time working through scenarios and debating the right rating, which often generates the most useful discussion of any part of the session.
Enhanced due diligence does not mean something exotic. It means going further: asking more targeted questions, digging deeper on web searches, repeating sanctions checks where the risk profile warrants it, and applying closer scrutiny throughout the life of the matter. We make this practical and apply it to the kinds of transactions your team actually handles.
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STEP 4 - SOURCE OF FUNDS AND SOURCE OF WEALTH ENQUIRIES
This is the area that generates the most questions in training sessions, and for good reason. It is also the area where the SRA most commonly finds that firms have done too little.
Source of funds and source of wealth are distinct concepts and we treat them separately.
Source of funds refers to the origin of the specific money being used in the transaction. The question is not simply which bank account the funds are coming from. It is how the client came to have those funds available for this transaction. Knowing that funds are held in a UK bank account is not sufficient.
Source of wealth refers to the economic activities and events that generated the client's overall net worth - not just the funds involved in this particular matter. It is particularly important where one source of funds is difficult to trace, where the matter is higher risk, or where something about the transaction is inconsistent with the client's apparent profile.
We use a three-question test to make this practical: where is the money, how did the client come to have it, and does the story ring true or ring alarm bells? We work through the kinds of evidence that should be obtained - bank statements showing the build-up of funds over time, sale completion statements, business accounts, inheritance documents - and what to do when the documents provided do not add up.
For established corporate clients with good Companies House records and market standing, public information may suffice in standard lower-risk cases. For individual clients in property transactions, bank statements are the baseline. For higher-risk matters or where enhanced due diligence applies, original documents should be obtained rather than copies or summaries.
We also work through what to do when something does not add up - because making further enquiries of the client is not tipping off, provided no suspicious activity report has been filed. Staff often underestimate how much they are permitted to ask before the tipping-off prohibition engages.
STEP 5 - RECORD KEEPING, ONGOING MONITORING AND DATA PROTECTION
Every step of an AML process must leave a documentary trace. If it is not on the file, the SRA takes the view that it was not done. We cover what good record-keeping looks like: writing up attendance notes and file notes at the time rather than retrospectively, recording web search results and screening tool outputs, documenting reasoning where a risk factor is identified and a decision is made not to escalate, and understanding the five-year minimum retention requirement under the Money Laundering Regulations.
Ongoing monitoring is not a one-off exercise completed at the point of onboarding. We cover the triggers that require a fee earner to revisit their initial assessment: material changes in the client's circumstances or beneficial ownership, transactions that are no longer consistent with what the firm knows about the client, and the development of any suspicion during the course of the matter.
The data protection dimension of AML work is covered specifically. Personal data obtained for AML purposes may only be used for those purposes. Firms must not retain it beyond what is necessary. This is an area that compliance teams often overlook when reviewing AML procedures and one that has become increasingly relevant as firms gather more data through electronic verification tools.
WARNING SIGNS, SUSPICIOUS ACTIVITY REPORTS AND TIPPING OFF
We spend dedicated time on what money laundering actually looks like in practice - not as an abstract concept but as a list of specific warning signs that fee earners can carry with them. These include clients with connections to higher-risk jurisdictions, unusually high fee offers, complex or layered ownership structures with no clear commercial rationale, third parties giving instructions with no explanation, cash-intensive businesses, requests to structure payments in instalments, clients who raise AML procedures proactively, and urgency used to discourage proper due diligence.
One of the most effective exercises in the session involves reading a hypothetical client enquiry and identifying every risk flag it contains before the group discusses the answer together. In our experience, this exercise reliably surfaces the kinds of disagreements within teams that make the subsequent discussion genuinely valuable.
On reporting, we cover the distinction between the primary offences under POCA and the suspicion threshold, following the Court of Appeal's analysis in R v da Silva.
We cover the internal SAR process step by step, the role of the MLRO in deciding whether to make an external report to the National Crime Agency, the consent regime and what a defence against money laundering means in practice, and the strict requirement to keep SAR documentation separate from the main file.
THE SRA AML BANKING FACILITY RULE
We include specific coverage of Rule 3.3 of the SRA Accounts Rules and the banking facility rule - an area that sits at the intersection of AML compliance and accounts obligations and one that is regularly misunderstood. The rule prohibits using a client account to provide banking facilities to clients or third parties. Payments into and out of the client account must have a direct connection with the delivery of regulated services.
We work through practical examples of what is and is not likely to be prohibited, which typically generates lively discussion and helps fee earners understand where the boundaries lie in their day-to-day work.
About your trainer
All training is delivered by Andy Donovan, a former practising solicitor & manager of the SRA GC team with over 15 years' experience in law firm regulatory work. Andy founded the Compliance Office and is now Director of Attuned Consulting.
Andy is a popular speaker at Law Society conferences and his commentary has been featured by BBC1, LexisNexis, Practical Law & The Law Society.
How we deliver AML Training for Law Firms
AML Training for Law Firms Service: what it looks like
AML Training for Law Firms FAQs:
We have delivered AML training to law firms of every size, from sole practitioners to training thousands of lawyers.
One of the things we are particularly experienced in is going deep with individual departments and practice area teams - running dedicated sessions for property teams, corporate teams, private client teams and compliance staff rather than delivering a single session to everyone at once. This approach works because the practical reality of AML compliance varies significantly from team to team. What a conveyancing fee earner needs to understand about source of funds is different from what a corporate lawyer needs to understand about beneficial ownership verification. Tailoring the session to the team makes the content stick in a way that generic all-staff training rarely achieves.
In person, we work with groups of around 15 to 20 people. That size allows us to break into small groups to work through case studies and exercises, with Andy moving around the room to see how each group is approaching the problem before bringing the discussion back together. This is where the real learning happens - not in the slides but in the disagreements, the edge cases and the questions that people have been meaning to ask for years.
While in-person sessions have clear benefits, online sessions are also fully viable and sometimes the only practical option available. For large groups, we use polls, chat and breakout exercises to maintain genuine engagement, recommend cameras on as a default, monitor attendance in real time and can apply a lock-out policy for late joiners. Recordings can be made available for internal use where agreed.
We are based in the Midlands, which puts us in a good position to deliver in-person sessions across a wide area. We regularly work with firms in Birmingham, Leicester, Nottingham, Oxford, Warwickshire and the wider Midlands, as well as London and firms across the North West, Yorkshire and the South West. We can also deliver AML training in Scotland. For firms further afield, we are always happy to discuss whether a combination of in-person and online sessions makes the most sense given the costs involved.
Every training project follows the same process. It is designed to keep things straightforward for you while ensuring the content we deliver is genuinely useful.
Step 1 - AML Training Planning call
Every project begins with a conversation. We want to understand your firm's practice areas, the experience levels in the room, any issues that have been causing difficulty and what you most need your team to take away. Most importantly, we want to know what you want to get out of the course.
Step 2 - Tailoring the training content
Where bespoke content has been agreed, we develop the materials following the planning call. For AML sessions, this typically means building case studies around your work types - conveyancing, corporate, private client or other practice areas - and exercises that reference your own client onboarding forms and procedures. The goal is that when a fee earner encounters a real situation, they recognise it.
Step 3 - AML Training Content Sign-off
We will normally share the proposed slides and session plan with you before delivery. You have the opportunity to refine, redirect or add to anything before we commit to the final version. We also use this stage to give you a clear steer on what will work best for your group on the day.
Step 4 - Delivery of the AML Training
The session is delivered in person or online, to a group or on a one-to-one basis, as agreed. We keep sessions as focused and practical as possible. The goal is not to get through the slides. It is to leave your team with something they can actually use when a file lands on their desk.
Step 5 - Follow-up
Following delivery, we provide a written record of attendance. For online sessions, we can provide a recording for internal use where agreed. Where a mop-up session has been arranged for staff who were unavoidably absent, that follows in the same format.
Do you only train fee earners or do you also train compliance staff and MLROs?
We train both, and the sessions are different. Fee earner sessions focus on practical application - what to do, when to do it and how to document it. Compliance staff and MLRO sessions go considerably deeper into the building blocks of the legislation, the regulatory expectations placed on nominated officers specifically, and how to build and run an effective AML compliance function.
We offer dedicated MLRO and MLCO training as a separate session, which is frequently delivered on a one-to-one or small group basis.
Is AML training a legal requirement for law firms?
Yes. For firms carrying out work subject to the Money Laundering Regulations 2017, training staff on AML obligations is a mandatory legal requirement, not a matter of best practice. Regulation 24 requires firms to take appropriate measures to make relevant employees aware of the law relating to money laundering and terrorist financing, and to regularly train those employees in how to recognise and deal with transactions and situations which may be related to money laundering or terrorist financing. The SRA actively checks whether firms have met this obligation when it visits, and the absence of adequate training has featured in a significant number of enforcement actions. Firms that cannot evidence a proper training programme are exposed both regulatorily and, in serious cases, legally.
How often should law firm staff receive AML training?
The Regulations require training to be provided regularly, and the SRA's expectation in practice is that staff should receive AML training at least annually and if there is a significant change in the law. Annual training ensures that staff are kept up to date with regulatory developments, that new risks and warning signs are covered, and that the firm can demonstrate an ongoing commitment to compliance rather than a one-off exercise. Firms in higher-risk practice areas, or those that have recently changed their procedures or onboarding systems, may want to consider more frequent sessions or targeted top-up training in addition to an annual programme. New starters should receive AML training as part of their induction and should not be handling regulated work unsupported before they have done so.
Who needs to receive AML training at a law firm?
Anyone involved in matter management or the AML process should receive appropriate training, and the scope is broader than many firms initially assume. This includes all fee earners handling regulated work, paralegals and legal assistants involved in client onboarding or matter progression, compliance staff and nominated officers, and support staff who play a role in the AML process - including reception or administrative staff who are asked to inspect or copy identity documents on behalf of fee earners. The key question is whether a member of staff could, in the course of their work, encounter a situation that requires them to recognise or respond to a money laundering risk. If the answer is yes, they should be trained. The SRA takes a broad view of this and firms should err on the side of inclusion when deciding who falls within scope.
Do the Money Laundering Regulations apply to all of our work?
No, not necessarily, and this is one of the most common areas of confusion. The Regulations apply to specific regulated work, including conveyancing, company formation, trust work and certain financial transactions. They ordinarily do not apply directly to litigation or most contentious work. However, that does not mean identity checks can be skipped. POCA 2002 applies regardless of whether regulated work is involved, and your firm's own procedures will typically require a baseline level of client identification across all matters. We cover this distinction carefully in every session.
How do you handle sanctions training - is that included?
Yes, sanctions compliance is covered as an integral part of every AML training session rather than as an optional add-on. We cover who must be screened, when to go further than the minimum, how to document the process, and the specific risk indicators the SRA expects firms to be alert to.
Can you tailor the session to our practice areas?
Yes, and in our experience, it makes a significant difference to how much the training lands. We regularly run separate sessions for conveyancing teams, corporate teams and private client teams, using case studies and exercises built around the transactions those teams actually handle.
How do you cover source of funds - it is the area our team finds most difficult?
It is the area most teams find most difficult, and it is the area the SRA most commonly identifies as deficient. In short, we get practical and bring things to life with real examples. We spend significant time on source of funds and source of wealth as distinct concepts, work through a three-question framework for approaching every case, cover what evidence should be obtained and why, and run a detailed case study that follows a transaction through from instruction to completion. By the end of the session, participants should have a clear and practical approach they can apply immediately.
Do you provide online AML training sessions for law firms?
Yes. Online sessions are fully viable and we make them work properly. We use polls, chat functions and scenario exercises to maintain engagement, recommend cameras on throughout, monitor attendance in real time and can apply a lock-out policy for late joiners. Recordings can be arranged for internal use where agreed in advance.
Where do you deliver in-person AML training?
We are based in the Midlands and deliver in-person sessions throughout England and Wales. We work regularly with firms in Birmingham, Leicester, Nottingham, Oxford, London and across the North West, Yorkshire and the South West. We can also deliver in Scotland. For firms further afield, we are happy to discuss whether a combination of in-person and online sessions makes the most practical sense.
