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Remote and Hybrid Working: Client Due Diligence under the Money Laundering Regulations 2017—Risk Assessment, E‑Verification, Deepfake Mitigation, Reliance and Practical Controls for Law Firms

Published on: 09 April 2024

Published by a LexisNexis Risk & Compliance expert

Legal News

Article summary

See Q&A: What CDD challenges could remote working present?

If your practice falls within the scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended, you are required to meet the statutory obligations at all times, regardless of how or where you work. The coronavirus (COVID-19) outbreak drove a broad move to remote working that largely persists; nevertheless, confirming who your client is and checking their identity remains essential and central to client due diligence (CDD). Offenders did not stop during the pandemic and some attempted to exploit the circumstances. With remote and hybrid models enduring, many of the CDD issues first examined then are still pertinent, as criminals continue seeking opportunities to take advantage. You should factor the risks of representing clients without an in-person meeting into your firm-wide risk assessment (FWRA). That assessment must in turn flow through into the policies, controls and procedures you implement to mitigate the risks you have identified. For further detail on firm-wide risk assessments, see subtopic: Risk assessment—law firms...

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