Client Account Online AML Risk Assessment

Firms details

Registered Business name *

Registered Business Address *

Name of MLRO *

Name of Main Client Account Online contact *

Contact Number *

Email Address *

1. Can you confirm the overall inherent AML risk rating for the practice? (as submitted to the Law Society Scotland in your most recent return) *

High

Medium high

Medium

Low medium

Low

2. Have there been any significant changes since the submission of your most recent AML Risk Assessment to the Law Society? *

Yes

If yes, please comment on the changes

3. In the last 12 months have you been subject to any anti-money laundering (AML) investigations that resulted in action by the FCA/Law Society or any other regulatory body you're registered with? *

Yes

If yes, please explain the investigations

Policies and Procedures

4. Does your practice have clear and adequate AML Policies, Controls and Procedures (PCPs) covering the requirements of r.19? Please refer to link (i) below. *

Yes

If no, please comment on PCP's

5. Are your AML systems and controls audited, either internally or externally? *

Internally

Externally

Neither

If neither, please give further details

6. Has your practice provided and documented AML training to staff in line with the requirement of r.24? Please refer to link (ii) below. *

Yes

7. Has your practice applied due diligence measures across all relevant business matters as required and set out in r.28 – 35? Please refer to link (iii) below. *

Yes

If no, please provide additional information on which measures are not in place

Please answer the remaining questions below in relation to the client accounts held / intend to be held with Scottish Building Society.

Geographical Risk

13. Does the Practice generally act for UK clients and very few (if any) who operate out with the UK/EU? *

Yes

If no, please comment on location of clients

14. Does the practice receive funds (into CAO) from a high-risk third countries (HRTCs)? r.28 – 35. Please refer to link (iii) below. *

Yes

If yes, please explain

Product/Services Risk

15. Is the Client Account Online facility used mainly for Executory Funds and Wills? *

Yes

If no, please add more information

16. If you use the accounts for other matters e.g. Conveyancing, Trust or Company Service Provision please provide additional details.

17. Does the Practice receive requests to carry out work out with its usual area of coverage? *

Yes

If yes, please comment on requests

Delivery Risk

18. Does the practice always meet all clients face to face? *

Yes

If no, please provide additional details on the approach taken by the firm to identify and verify their clients remotely.

19. Does the Practice undertake any work which is conducted through intermediaries or third parties? *

Yes

If yes, please comment on the work

Transactional Risk

20. Does the Practice get regularly involved in transactions which are undertaken at short notice, quick turnaround or high volumes? *

Yes

If yes, please comment on transactions

21. Is there any additional relevant information in relation to your Client Account Online facility that you should make us aware of ?

Declaration

The information provided is correct at the time of completion *

The information has been provided by a company official with relevant anti-money laundering responsibilities – for example, a Money Laundering Reporting Officer, nominated officer, or similar role if neither are appointed. *

The Practice are a corporate body or an unincorporated body. *

The Practice is registered with the Law Society of Scotland at the registered address provided on this questionnaire and the firm fully complies to Money Laundering Regulations (ML regs), The Proceeds of Crime Act 2002 (PCA) and the Terrorism Act (TACT). *

We agree to provide, upon written request, information on the identity (including verification documents and/or source of funds confirmation) of the owners of the funds held in the Client Accounts. *

All accounts held through Client Account Online opened will be in adherence to the Money Laundering Regs and the Society’s Terms and Conditions and will be held by me/us as a trustee for a named client. *

We have already been provided with and fully understand the Terms and Conditions of the Client Account facility and can be found below. *

Thank you for completing this questionnaire. You don't need to do anything – we'll contact you with any updates or if we need more information. Please type full name here *

Please type position/role here *

Date form completed *

Client Account Online AML Risk Assessment

Client Account Online AML Risk Assessment

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