Anti-bribery & corruption

This Practice Note outlines the regulatory obligations concerning anti-money laundering ( AML), counter-terrorist financing ( CTF) and counter-proliferation financing record keeping set out in the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, as amended. You should verify whether the MLR 2017 include any additional or altered requirements for your sector, and whether your regulatory body sets further, sector-specific expectations in relation to record keeping. If the MLR 2017 apply to you, you must establish and maintain appropriate, risk-sensitive policies and procedures relating to record keeping. Record keeping is a core element of the AML, CTF and counter-proliferation financing framework because it: demonstrates your compliance with regulatory obligations; and assists law enforcement agencies in carrying out financial...

The Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, constitute part of the UK’s overarching anti-money laundering ( AML), counter-terrorist financing ( CTF) and counter-proliferation financing framework, as amended. The MLR 2017 prescribe administrative obligations that operate alongside the criminal limbs of the AML, CTF and counter-proliferation financing regime found in the Proceeds of Crime Act 2002 ( POCA 2002), the Terrorism Act 2000 ( TA 2000) and a range of sanction measures. Some provisions intersect with that legislation. Since June 2017, the MLR 2017 have been amended on several occasions. This Practice Note reflects the MLR 2017 in their amended form. For further information on POCA 2002, TA 2000 and counter-proliferation financing, refer to the Practice Notes: Proceeds of Crime Act 2002;...

This Practice Note explains when organisations are required to appoint a nominated officer (often called a money laundering reporting officer, or MLRO), outlines the nominated officer’s responsibilities, and suggests practical actions they can take to carry out the role. It reflects the obligations set by the Money Laundering Regulations 2017, SI 2017/692 ( MLR 2017), as updated. The guidance is intended for general use. You should confirm whether your regulator imposes any additional, sector‑specific expectations concerning nominated officers. What is a nominated officer? A nominated officer is the individual designated to receive and evaluate suspicious activity reports ( SARs) under the Terrorism Act 2000 ( TA 2000) and the Proceeds of Crime Act 2002 ( POCA 2002). They are also expected to submit external SARs to the National Crime Agency ( NCA). The nominated officer is different from the MLCO, ie the...

This Practice Note outlines the central duties relating to sources of funds and wealth, and draws out the distinction between the two concepts. It also explains what to do if you are concerned. The guidance is of general application, alongside specific direction for firms overseen by the SRA for anti‑money laundering ( AML) purposes. If you are not a legal practice and/or the SRA does not act as your AML supervisor, you should confirm whether different or additional requirements apply in your sector and whether your regulatory body imposes further, sector‑specific expectations about source of funds and wealth. Source of funds v source of wealth The two terms are not synonymous; while they may overlap substantially, they are interconnected rather than standalone. They should not be viewed in isolation from one another in each case accordingly. Source of funds concerns where the monies used for...

Legal professional privilege ( LPP) is a core legal protection that permits [ insert organisation’s name ] to resist producing evidence to a third party or the court. It enables the organisation to seek expert legal guidance, setting out all pertinent facts to our legal advisers without concern that they will later be revealed and used against us. This short guide sets out what legal professional privilege ( LPP) is and how we can best preserve it. 1 What is legal professional privilege? LPP is an umbrella term covering: legal advice privilege ( LAP) litigation privilege LPP safeguards the confidentiality of written and verbal communications between lawyers and clients. It is a fundamental entitlement, allowing a party to withhold material from disclosure to any third party or a court. Legal advice privilege Legal advice privilege applies to all confidential...

Organisations caught by the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692 must: apply enhanced customer due diligence ( CDD) measures and strengthened ongoing monitoring for any transaction or business relationship with a person established in a high-risk third country not place reliance on a third party established in a high-risk third country The obligation to undertake enhanced due diligence in relation to high-risk third countries applies where there is a relevant transaction and an establishment in a high-risk third country. A relevant transaction is one for which you are required to apply CDD under MLR 2017, reg 27, and being established in a country means: for a legal person, being incorporated in, or having its principal place of business in, that country, or—where a financial...

Several offences relating to tipping-off and prejudicing an investigation apply within the regulated sector. An additional offence of prejudicing an investigation applies exclusively to the unregulated sector. Both sectors are also exposed to a further offence involving interference with documents. This Practice Note outlines the offences of tipping-off and prejudicing an investigation under the Proceeds of Crime Act 2002 ( POCA 2002). It mirrors the requirements of the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, as amended. For details on what forms the regulated sector, see Practice Note: Money laundering—key information for businesses. Suspicious activity report ( SAR) The principal money laundering offences are: concealing criminal property being party to an arrangement that enables money laundering possessing criminal property POCA 2002 requires knowledge or suspicion of money laundering to be reported by submitting a SAR. You will have a...

You may owe a regulatory or professional obligation to preserve the confidentiality of your customers’ affairs, and the situations in which you are permitted to reveal details about a customer can be highly restricted. The Proceeds of Crime Act 2002 ( POCA 2002) creates a duty to report knowledge or suspicions of money laundering by submitting a suspicious activity report ( SAR). Significant criminal penalties apply if you fail to comply. The Terrorism Act 2000 ( TA 2000) also imposes a disclosure requirement where you know or suspect that another person has committed, or is about to commit, a principal terrorist property offence. Counter-proliferation financing is the newest component within the long-standing anti-money laundering ( AML) and counter-terrorist financing ( CTF) framework. Obligations concerning counter-proliferation financing were brought into the Money Laundering, Terrorist Financing and Transfer of Funds (...

Practice Note Under the Proceeds of Crime Act 2002 ( POCA 2002) and the Terrorism Act 2000 ( TA 2000), you must report knowledge or suspicions of money laundering and terrorist financing to the National Crime Agency ( NCA) by submitting a Suspicious Activity Report ( SAR). Failure to report attracts significant criminal penalties. A SAR can be: an internal SAR to the organisation’s nominated officer, or an external SAR to the NCA This Practice Note sets out practical guidance for the nominated officer on making an external SAR to the NCA and on obtaining a defence or consent to carry out a prohibited act (that is, to proceed with a matter you know or suspect involves money laundering or terrorist financing). See also Practice Note: Reporting suspicions of money laundering and terrorist financing for more detailed information on the law governing the SARs...

This Practice Note This note sets out the obligations contained in the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, as amended. It also aligns with guidance issued by the Joint Money Laundering Steering Group ( JMLSG) and the Legal Sector Affinity Group ( LSAG) AML guidance for the Legal Sector. Frequently, a customer may engage other advisers or be in professional contact with relevant persons on the same matter. For instance, in a major transaction the customer might also instruct accountants or tax professionals. Likewise, the customer may already be working with a different part of your business group. Repeated requests for identical information from multiple advisers and business partners can be needlessly duplicative and frustrating for the customer. To address this, the MLR 2017 permit reliance on others to perform customer due...

The Proceeds of Crime Act 2002 ( POCA 2002) took effect on 24 February 2003 and applies to money laundering conduct from that date onwards. The point in time when the underlying crime occurred does not matter for these purposes. Offences POCA 2002 creates several money laundering offences, including: three core offences of: concealing, arranging, and acquiring failure to disclose tipping-off and prejudicing an investigation The principal offences apply to all individuals. Certain failure to disclose and tipping-off provisions only cover those working within the regulated sector. For more on what constitutes regulated sector activity, see Practice Note: Money laundering—key information for businesses. The principal offences POCA 2002 replaced the parallel drug and non-drug laundering offences previously found in the Criminal Justice Act 1988 and the Drug Trafficking Act 1994, representing a significant shift. The three principal offences—concealing, arranging and acquiring—no longer draw a line between proceeds of drug...

STOP PRESS: This document is being updated to reflect implementation of the Data ( Use and Access) Act 2025 ( DUAA 2025) which amends the UK GDPR and Data Protection Act 2018. For detailed help on DUAA 2025’s compliance impact, consult Practice Note: Data ( Use and Access) Act 2025—compliance implications. The rules within the United Kingdom General Data Protection Regulation ( UK GDPR), the Assimilated Regulation ( EU) 2016/679, and the Data Protection Act 2018 ( DPA 2018) pose particular difficulties for the anti-money laundering ( AML), counter-terrorist financing ( CTF) and counter-proliferation financing framework, such as: pinpointing a lawful basis to handle personal data meeting transparency and information duties safeguarding client information gathered through client due diligence ( CDD) disclosing client details to law enforcement bodies, for example via suspicious activity reports ( SARs), and dealing with data...

Released in July 2025, the UK’s fourth National risk assessment ( NRA) on money laundering and terrorist financing sets out the principal money laundering and terrorist financing risks facing the UK, and highlights how these have evolved since the government’s previous NRA, issued in 2020. This Practice Note summarises the NRA’s context, sets out its key findings, and explains what the report’s publication means for you. Background Under the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, as amended, the Treasury and Home Office are required to put in place arrangements for a risk assessment to be carried out to identify, assess, understand and mitigate the money laundering and terrorist financing risks affecting the UK......

As part of your customer due diligence ( CDD) measures, you must keep your business relationships under continual review. This Practice Note outlines the ongoing monitoring obligations set out in the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, as amended. The guidance is of general applicability. You should verify whether the MLR 2017 contain additional or different duties for your sector and whether your regulatory body sets any further, sector specific expectations regarding ongoing monitoring. Counter-proliferation financing is the most recent element of the long-established anti-money laundering ( AML) and counter-terrorist financing ( CTF) regime. Amendments to the MLR 2017 introduced requirements relating to, for instance, systems and controls, risk assessment, etc. No specific counter-proliferation financing rules were added to CDD, and the existing CDD provisions in the MLR 2017 were not...

This Practice Note summarises counter-terrorist financing ( CTF) measures, covering the offences and duties found in the Terrorism Act 2000 ( TA 2000) and associated laws. It explains what constitutes terrorist financing, how it intersects with the anti-money laundering ( AML) framework, and why it matters for businesses. What is terrorist financing? Terrorist groups require money to organise and execute attacks. The TA 2000 makes both involvement in terrorist activity and the financing of terrorism criminal offences. Broadly, terrorist financing covers supplying or gathering funds from lawful or unlawful sources, intending, or knowing, that they are to be used to commit an act of terrorism, regardless of whether the money is ultimately applied to that end. Counter-terrorist financing and anti-money laundering CTF and AML are distinct concepts, though their objectives overlap. Within UK law, the CTF and AML regimes operate alongside each other. Numerous...

This Practice Note outlines the obligations of the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, regarding the screening of relevant employees and the approval of beneficial owners, officers and managers ( BOOMs), together with best practice for vetting staff for anti-money laundering ( AML) compliance roles, even where the MLR 2017 do not apply. This Practice Note mirrors the requirements of the MLR 2017, as amended, and supplies guidance that is of broad, general application. You should verify whether the MLR 2017 contain additional or varied obligations for your sector and whether your regulatory body has any further, additional, sector specific requirements in relation to screening employees within your organisation. Screening requirements in the MLR 2017 If the MLR 2017 apply to your organisation, you must conduct screening of relevant...

Customer due diligence ( CDD) This Practice Note outlines guidance on customer due diligence ( CDD), a key element of the anti-money laundering ( AML) and counter-terrorist financing ( CTF) framework. CDD duties underpin the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692, as amended. You should verify whether the MLR 2017 set out any additional or modified obligations for your sector and whether your regulatory body imposes further, sector-specific CDD requirements. Counter-proliferation financing is the latest addition to the long-established AML and CTF regime. Amendments to the MLR 2017 introduced counter-proliferation financing measures relating to systems and controls, risk assessment, etc. No counter-proliferation financing provisions were added specifically to CDD, and the existing CDD rules in the MLR 2017 were not revised to reference proliferation financing....

Issues of confidentiality arise in two different respects in terms of suspicious activity reports ( SARs): your professional or regulatory obligation to keep client matters confidential (where such a duty exists) the need to preserve the confidentiality of the SAR itself Both raise distinct, but related, confidentiality considerations. This Practice Note addresses both strands in practical detail. It offers guidance of broad, general application. You should confirm whether legislation or your regulator imposes any extra, sector‑specific confidentiality obligations beyond this guidance. Counter‑proliferation financing is the latest component of the long‑established AML/ CTF framework, recently incorporated into regulation. Obligations concerning counter‑proliferation financing were brought into the Money Laundering, Terrorist Financing and Transfer of Funds ( Information on the Payer) Regulations 2017 ( MLR 2017), SI 2017/692 via the Money Laundering and Terrorist Financing ( Amendment) ( No. 2) Regulations 2022, SI 2022/860. Although the CPF...

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...