Sector assessment
10 laundering methods apply to this sector. 5 are rarely covered in standard AML training. The sector assessment uses 7 cases.
Law firms complete the step that gives a structure legal effect, and the client account is the part other institutions trust without looking behind it.
Checks are performed on the matter in front of you rather than on the arrangement it belongs to. A repossession where the former owner continues to manage the property, or a loan-back dressed as a family advance, is only visible if somebody looks past the file they were given.
SRA Accounts Rules rule 3.3 prohibits using a client account to provide banking facilities, and the SRA's warning notice on it has been reissued repeatedly since 2014 with disciplinary outcomes attached. The 2025 National Risk Assessment treats legal-sector professional enablers as a rising risk.
A firm is in scope when it carries out relevant activity: conveyancing, company and trust formation, managing client money, or acting in the buying and selling of business entities. Pure contentious litigation sits outside it. Most firms of any size do at least one of the first four, which puts the firm in scope even where a given department is not.
Not one case. Every case that exercises a typology on your list is part of your mark, weighted by how much of your exposure it carries. The weights are derived from the register rather than chosen, so adding a case re-derives them instead of leaving the old ones wrong.
| Case | Your typologies | Share of your mark |
|---|---|---|
| The Client Accountwritten for your desk | 6 | 31% |
| The Relationship Review | 6 | 32% |
| The Client Engagement | 2 | 11% |
| The Private Client File | 2 | 11% |
| The Onboarding Interview | 1 | 5% |
| The Policy Book | 1 | 5% |
| The Sponsorship File | 1 | 5% |
£99one payment, 12 months, nothing renews
£750pilot, up to 25 people, invoiced
Drawn from the full register and filtered to this sector. Each entry states what the typology looks like inside your own systems, and names the source it came from. 10 of the 10 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
Deceased individuals are recorded as directors, officers and shareholders, and accounts opened by the living are run on after death. There is no accomplice who can be pressured, because the nominal principal is dead.
An account in good standing whose signatory died in a jurisdiction the firm does not search, filings continuing for a director with no verifiable life, and mandates never refreshed because the account never triggered a review.
Residence or citizenship is obtained through qualifying investment, converting funds of uncertain origin into a residency status that subsequently anchors banking relationships and asset holdings.
Source of wealth evidenced principally by the qualifying investment itself, onboarding shortly after grant of status, and jurisdiction of residence inconsistent with any economic or family connection.
Property is nominally lost to a creditor while beneficial ownership never changes, or is held through a dissolved foreign entity that remains the registered owner.
Repossession followed by continued occupation or management by the former owner, debt routed through a professional intermediary, and funds flowing back to the supposedly dispossessed party.
Borrowing is obtained on fabricated income, undisclosed deposits of criminal origin, or inflated valuations, and the loan both launders the deposit and generates a legitimate ownership record.
Deposits gifted by parties with no evidenced means, income documentation that cannot be corroborated with the employer or HMRC, valuations materially above comparable sales, and early full repayment shortly after completion.
Fabricated debt is guaranteed, defaulted, sued upon in a compliant jurisdiction and settled by court order, so proceeds arrive as a judgment rather than a payment.
Large inbound settlements supported by foreign court orders. The control weakness is that court-ordered recoveries are assumed clean and rarely receive enhanced due diligence.
A regulated professional's client account is used as a banking facility, lending the transaction the firm's own reputational cover and obscuring the underlying parties.
Client account movements with no underlying legal or accountancy transaction, funds returned to source shortly after receipt, and pooled balances that cannot be reconciled to matters.
Company formation, nominee director, registered office and trustee services are supplied at scale, assembling the structures other typologies depend on.
Clusters of customers sharing a registered office, a formation agent or a nominee, incorporated in batches, and presenting near-identical onboarding documentation.
Assets pass through the administration of a deceased person's estate, where the party whose funds they were is beyond enquiry. Due diligence is performed on executors and beneficiaries; the deceased is not checked, and the estate's assets move through a firm's client account before distribution.
Estate funds arriving from a professional's client account with no visibility of their origin; assets appearing in an estate that the deceased's known circumstances do not explain; and a firm that is itself the executor, where no external party sees the administration at all.
Clubs, sponsorship and image rights provide a channel for funds with weak valuation discipline, cross-border payments and a reputational shield that discourages scrutiny.
Club funding by shareholder loan from opaque structures, sponsorship values with no commercial benchmark, agent and image-rights payments routed through unrelated jurisdictions, and transfer fees inconsistent with market.
Criminal funds are placed offshore and then lent back to the launderer, so the money returns as borrowing, complete with a repayment schedule, an interest deduction and an apparently arm's-length lender.
Borrowing from an offshore entity with no lending business, security or guarantees provided by parties connected to the borrower, interest paid to a jurisdiction unrelated to the transaction, and loans that are never enforced when they fall into arrears.
The Client Account carries 6 of the 10 typologies above and 31 per cent of your mark. Full debrief, no account, no card.
Start The Client AccountRun the full Legal benchmark across up to 25 people for £750.
No integration · No customer data · Confidential cohort available
One documented case each week. One decision. The answer and the source afterwards.
