Scoping
Classifying the practice's services and documenting precisely which fall within the activities in scope.
Sectors under AML supervision
AML Compliance for Lawyers and Notaries
Scope attaches to defined activities you carry out for clients, not to holding the professional title.
Independent legal professionals are a designated non-financial business category, but their scope is not absolute — and this is the point most often misunderstood. A lawyer does not carry AML obligations simply by being a lawyer.
Scope arises when carrying out defined activities for a client: managing funds or assets, forming or managing companies, and arranging or disposing of ownership. Litigation and giving legal opinion sit differently.
So our first step is not building the framework but scoping it precisely: which of your services fall inside and which fall outside. Building a framework wider than necessary burdens the practice for nothing.
What your business must do
Client due diligence
Verifying client and beneficial owner identity, specifically for work in scope.
Source of funds
Understanding and documenting the source of funds in work of a financial nature.
Professional privilege boundaries
Handling the relationship between confidentiality and reporting obligations in a disciplined way — an area that needs clarity set in advance, not improvised in the moment.
Client accounts
Controls over client money accounts where the practice operates them.
Training and documentation
Training lawyers and administrators on the indicators, and documenting every due-diligence step.
Risk indicators in this sector
- A client asking to route funds through the firm's account without justification
- A transaction whose value does not match the apparent legal file
- A third party paying fees with no clear relationship to the client
- Unexplained urgency in completing an ownership arrangement
- A client avoiding direct contact and resisting documentation
Our services for this sector
Frequently asked questions
Is all of the firm's work in scope?
No. Scope attaches to defined activities. Scoping precisely is the first thing we do, and it saves the practice considerable effort.
How do we reconcile privilege with reporting?
Written boundaries are set in advance within the policies, so the team knows when each consideration applies rather than leaving it to judgement in the moment.
Do we need a full-time compliance officer?
Not necessarily. Many practices suit an outsourced arrangement with defined scope, particularly where work in scope is a limited part of their activity.