The AML Clinic Podcast

In this episode of the AML Clinic podcast, host Michelle Clement, a former SRA AML Regulatory Manager, explores the often-overlooked aspect of recruitment in the context of AML compliance. Joined by Lauren Eager, a principal consultant at QED Legal, they discuss how hiring decisions reflect a firm's operational priorities, investment in compliance, and response to regulatory pressures. The conversation highlights the divide between firms that proactively build compliance teams and those that react only under pressure.

In this concluding episode of a three-part series, The AML Clinic Podcast brings together the core themes explored across the trilogy: how the SRA assesses seriousness, what it looks for in AML file reviews, and how internal decision-making shapes regulatory outcomes.Michelle Clement (former SRA AML Regulatory Manager) focuses on where outcomes are truly determined in practice, at the point where risk is interpreted and judgement is applied.Grounded in real-world environments, this episode explores:how risk is interpreted under pressure why consistency remains difficult across firms where technically complete files fall short what supports defensible decision-making Designed for partners, MLROs, MLCOs and compliance professionals, this final instalment offers a clear view of what determines whether your AML approach stands up to scrutiny.

 In this episode, former SRA AML Regulatory Manager Michelle Clement explains what the SRA actually looks for when reviewing your files, why technically complete files often fall short, and how to ensure your approach stands up to scrutiny. 

 In this episode of the AML Clinic Podcast, Michelle Clement explores how the SRA determines whether a breach is “serious” in practice. Understanding how to evaluate the seriousness of breaches is essential for law firms. Many firms grasp the rules, but fewer truly understand how the SRA assesses seriousness. Knowing this can help you make defensible decisions and avoid unnecessary panic when issues arise. 

In this episode, the tables are turned as I’m interviewed by Pearl Moses, the Former Head of Risk and Compliance at the Law Society who came prepared with questions gathered from AML professionals across the legal sector.We discuss the biggest AML mistakes many law firms make, what ''does it make sense” means in practice, and how firms can challenge factual inaccuracies or misinterpretations during SRA engagement.We also explore what the SRA looks for when reviewing files, what the FCA's take over means for the legal sector today, and why firms should focus on building defensible AML frameworks that stand up to scrutiny.

In this episode of the AML Clinic podcast, host Michelle Clement engages with Colin Solomon, a senior specialist in offshore financial services, to explore the complexities surrounding offshore jurisdictions and their associated AML risks. The conversation delves into why offshore entities are deemed inherently risky, emphasising the need for a nuanced understanding of risk that transcends simplistic categorisations. Solomon argues that while there are bad actors in offshore jurisdictions, the perception of risk is often influenced by regulatory caution and media narratives. He provides practical insights for law firms on how to assess offshore structures and beneficial ownership, advocating for a risk-based approach that prioritizes understanding over assumptions.

What would it mean for law firms if AML supervision shifted from the SRA to the FCA? And what can the legal sector learn from financial services right now?In this episode of The AML Clinic Podcast, Michelle is joined by Chantelle Obatolu, Financial Crime Specialist and Assistant Vice President in AML at Sumitomo Mitsui Banking Corporation. With extensive experience across global banks and consulting firms, Chantelle shares practical insight into how the FCA approaches AML supervision in practice.They discuss:The FCA’s supervisory style and what reviews look like in realityHow deep the FCA goes into governance, systems, culture, and filesAML reporting expectations and how data drives supervisionSenior accountability under the SMCR What effective remediation looks likeWhat law firms can do now to be “FCA-ready”Whether or not formal change happens, expectations around accountability, evidence, and risk management are rising. This episode offers clear, practical lessons for MLROs, compliance leaders, and law firm decision-makers navigating an evolving regulatory landscape.Tune in to stay informed, stay compliant, and stay ahead.

In this episode of the AML Clinic podcast, host Michelle Clement and guest Ray Blake delve into the complexities of onboarding a corporate client within the framework of anti-money laundering (AML) compliance. They explore the critical distinctions between identifying and verifying corporate clients, the role of Special Purpose Vehicles (SPVs), and the importance of understanding ownership structures. The conversation highlights the red flags associated with SPVs, the limitations of relying solely on Companies House for verification, and the regulatory requirements for directors. The episode concludes with practical advice for firms navigating due diligence processes, emphasising the need for thorough documentation and understanding of the regulatory landscape.

In this episode of The AML Clinic Podcast, Michelle Clement speaks with Christian Hunt, author of Human Risk, about why compliance failures in law firms are rarely caused by bad individuals and are more often the result of poorly designed systems.They explore how behavioural science can improve AML and compliance outcomes, why traditional approaches like policies and training often fail, and how firms can better engage legal professionals in day-to-day compliance decision-making.A practical conversation for AML, compliance and risk professionals working in or with law firms.

In this episode of the AML Clinic podcast, host Michelle Clement interviews Luke Haddon, the money laundering reporting officer at Keystone Law. They discuss Luke's career path, the proposed changes to the UK's money laundering regulations, and the implications of these changes for law firms. Luke expresses concerns about the introduction of pooled client accounts and emphasizes the importance of a risk-based approach to compliance. He also highlights the need for a collaborative culture between compliance teams and legal practitioners to ensure effective compliance and protect clients' interests.

In this episode of the AML Clinic Podcast, Michelle Clement and Eloise Butterworth discuss the evolving legislative landscape for law firms, focusing on AML compliance, resourcing hurdles, and the role of technology. Eloise shares her journey from family law to risk and compliance, emphasising the importance of clarity, training, and culture in managing AML obligations. They also explore the financial viability of law firms while meeting compliance standards and bust common myths about AML practices.Links referencedSRA annual report -solicitors-regulation-authority-limited-financial-statements-2024.pdfSRA training checklist - aml-training-checklist.pdfSRA | Sole practitioners' and small firms' use of technology and innovation | Solicitors Regulation AuthoritySee Customer due diligence section - SRA | Compliance with the regulations and preventing money laundering Q&A | Solicitors Regulation Authority

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation also covers the concept of criminal property, the Spanish bullfighter exception, and the balance between confidentiality and reporting obligations. TakeawaysVerifying source of funds in transactional and non transactional matters.The role of the MLRO in anti-money laundering compliance.Learn about the concept of criminal property under POCA.Explore the Spanish bullfighter exception in legal contexts.Balance confidentiality with reporting obligations in legal practice.Identify the challenges of anti-money laundering compliance.Discuss the principle of fungibility in financial transactions.Examine the role of legal professional privilege in reporting.Highlight the need for ongoing training in compliance.Spanish Bullfighter LSAG reference https://www.sra.org.uk/globalassets/documents/solicitors/firm-based-authorisation/lsag-aml-guidance.pdf#=page193

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation also covers the concept of criminal property, the Spanish bullfighter exception, and the balance between confidentiality and reporting obligations. TakeawaysVerifying source of funds in transactional and non transactional matters.The role of the MLRO in anti-money laundering compliance.Learn about the concept of criminal property under POCA.Explore the Spanish bullfighter exception in legal contexts.Balance confidentiality with reporting obligations in legal practice.Identify the challenges of anti-money laundering compliance.Discuss the principle of fungibility in financial transactions.Examine the role of legal professional privilege in reporting.Highlight the need for ongoing training in compliance.

In this episode of The ANL Clinic, we dive into one of the most critical and often misunderstood  areas of financial crime prevention: the difference between source of funds and source of wealth.We explore a real Solicitor Disciplinary Tribunal case involving a politically exposed person, a £1.1 million transaction and a £1.9million transaction, and serious gaps in due diligence.Key takeaways:Why distinguishing source of funds vs source of wealth mattersThe risks of relying on third-party assurancesHow compliance failures can lead to disciplinary actionSRA | Thematic review of source of funds and wealth compliance | Solicitors Regulation Authority

In this episode of the AML Clinic podcast, host Michelle Clement interviews Christopher Christou, a solicitor who shares his experiences with SRA AML inspections. The conversation covers the emotional journey of receiving an inspection notice, the preparation involved, and the importance of compliance in law firms. Christopher discusses the challenges of running a small firm, the role of technology in compliance, and the need for a culture of compliance within teams. The episode concludes with myth-busting in AML compliance, emphasising the importance of diligence and awareness in the legal profession.Links SRA | Guidance on our firm inspections | Solicitors Regulation AuthoritySRA | Sole practitioners' and small firms' use of technology and innovation | Solicitors Regulation Authority

In this episode of the AML Clinic, Michelle Clement and Graham Mackenzie discuss the critical issue of money laundering in law firms. They explore the vulnerabilities within legal services, particularly in conveyancing, the role of trust and company service providers (TCSPs), and the implications of tax advice. The conversation also addresses the risks associated with probate and busts the myth that firms without client accounts are not at risk of being used for money laundering. The episode emphasizes the importance of understanding the source of funds and the impact of legal work on local communities.