Money Laundering Policy

All solicitors’ firms are subject to strict controls under the Money Laundering Regulations 2017 and  the Proceeds of Crime Act 2002 which are designed to detect and ensure reporting of offences such  as tax evasion or benefit fraud. We are therefore obliged to check identity and residence from all  clients. To do this we will require to inspect original passports and/or photocard drivers’ licences  AND at least two further documents i.e. recent utility bills, credit card or mortgage statements (in  either case, not more than 3 months old). 

It is the firm’s policy that we will also require any funds that come into the firm to be paid by bank  transfer or cheque. If a third party’s money is used, we will also require similar identification details  for them. We are also obliged to determine the source of any funds utilised in or deriving from the  transaction and this may involve asking the individual personal questions. In the event that any  client, or third party, refuses to answer such questions, we must reserve the right to terminate the  business relationship and the consequences set out below may then follow. You will still be liable for  all our fees and expenses incurred up to the date of termination. 

In the event that we become aware or suspect that a client is intending to utilise this firm for money laundering purposes (i.e. passing through our client account the proceeds of any criminal activity), then we are required by law to report the client to the National Crime Agency (NCA). NCA can pass the information received to any relevant body such as HM Revenue & Customs and an investigation  may take place at any time in the future. Only to the extent required to enable us to comply with  the law and file such reports, you agree to waive your privilege (i.e. confidentiality) rights with this  firm. We are not permitted to inform clients that we have made such a report nor, once such a report  has been made, are we able to speak to that client or anyone else involved in the transaction until  we receive clearance from NCA, which may take anything up to 36 days to obtain. 

NCA may even withhold permission for us to continue with the case. It follows from the above that,  if you have any concerns about irregularities in your financial position, we strongly recommend that you seek specialist accountancy or welfare benefits advice to correct those irregularities before instructing us.

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