CDD · Source of Funds · Risk Rating · Decision Records
A structured AML workflow for conveyancing solicitors — covering client due diligence, source of funds assessment, property risk rating and a compliant MLRO decision record.
Enter transaction type, property details, purchase price, mortgage position and matter reference. Covers residential and commercial conveyancing.
Structured CDD, identity verification, source of funds documentation and beneficial ownership tracing — with LÆdar AI-assisted sanctions and PEP screening.
A complete property-specific AML decision record aligned to LSAG 2023 and MLR 2017 — with risk rating, MLRO decision and documented rationale. Print or export as PDF.
The workflow covers all property transaction types with specific AML guidance and source of funds assessment tailored to each scenario.
AML guidance tailored to each property transaction type — residential purchases, remortgages, transfer of equity, new builds, commercial and auction purchases.
Structured source of funds assessment for mortgage, savings, sale proceeds, gifted deposits, inheritance and other fund sources — with documented plausibility analysis.
Real-time Companies House search, sanctions screening via LÆdar, and property price benchmarking — integrated directly into the workflow.
Produces an audit-ready AML file note aligned to LSAG 2023 and MLR 2017 — with risk rating, MLRO decision and full documented rationale. Print or export as PDF.
Access the LÆdar Conveyancing AML Workflow.
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Request access: contact@kycifi.com
A structured AML workflow for conveyancing solicitors. Capture matter details, verify client identity, assess source of funds, and generate a compliant file note — all in one guided form.
Provide the core details of the property transaction. This information is used to calibrate the risk assessment throughout the remaining steps.
No data is transmitted or stored. All information remains in your browser. Use the print or export function at the final step to save the completed AML file note.
Record identifying details for each client on this matter. Nationality, country of residence, and PEP status directly inform the risk rating at Step 5.
Cash buyer — elevated source of funds scrutiny required. No mortgage lender will conduct independent AML checks on this transaction. You must obtain, verify, and document satisfactory source of funds evidence before exchange. Refer to LSAG Guidance (2023) s.4.3 and your firm's cash buyer procedure.
Non-UK resident client. Consider whether certified copies of identity documents are required and document your chosen verification approach. Ensure satisfactory proof of overseas address is obtained. Refer to SRA AML guidance on non-face-to-face customer due diligence.
FATF increased monitoring jurisdiction. The client's country of residence is currently on the FATF Grey List (subject to increased monitoring). Enhanced scrutiny is recommended. Document all additional checks undertaken and consider whether Enhanced Due Diligence is proportionate for this matter.
FATF High-Risk Jurisdiction — Call for Action. The client's country of residence is subject to the FATF call for action. Enhanced Due Diligence is mandatory under Reg. 33 MLR 2017. Carefully consider whether to accept or continue this instruction and document all enhanced scrutiny measures applied. Senior management sign-off is required.
PEP identified. Enhanced Due Diligence is mandatory under Reg. 35 MLR 2017. Senior management approval is required before establishing or continuing this business relationship. Source of wealth and source of funds must be documented with enhanced rigour, and the relationship must be subject to ongoing monitoring.
Adverse media or sanctions match identified. Document the nature and source of findings, assess their materiality and relevance to this matter, and determine whether Enhanced Due Diligence is required. Consider escalation to your MLRO before proceeding.
Non-UK resident client. Consider whether certified copies of identity documents are required and document your verification approach. Ensure proof of overseas address is obtained.
FATF increased monitoring jurisdiction. The client's country of residence is on the FATF Grey List. Enhanced scrutiny is recommended. Document all additional checks undertaken.
FATF High-Risk Jurisdiction — Call for Action. Enhanced Due Diligence is mandatory under Reg. 33 MLR 2017. Document all enhanced scrutiny measures applied and obtain senior management sign-off before proceeding.
PEP identified. Enhanced Due Diligence is mandatory under Reg. 35 MLR 2017. Senior management approval required before proceeding. Document source of wealth with enhanced rigour.
Adverse media or sanctions match identified. Document findings, assess materiality, and consider whether EDD is required. Consider escalation to your MLRO before proceeding.
Non-UK resident client. Consider certified copies for identity documents and document your verification approach. Ensure proof of overseas address is obtained.
FATF increased monitoring jurisdiction. Country of residence is on the FATF Grey List. Enhanced scrutiny is recommended. Document all additional checks undertaken.
FATF High-Risk Jurisdiction — Call for Action. EDD is mandatory under Reg. 33 MLR 2017. Senior management sign-off required before proceeding.
PEP identified. EDD mandatory under Reg. 35 MLR 2017. Senior management approval required. Document source of wealth with enhanced rigour.
Adverse media or sanctions match identified. Document findings, assess materiality, and consider EDD. Consider escalation to your MLRO before proceeding.
Non-UK resident client. Consider certified copies for identity documents and document your verification approach. Ensure proof of overseas address is obtained.
FATF increased monitoring jurisdiction. Country of residence is on the FATF Grey List. Enhanced scrutiny is recommended. Document all additional checks undertaken.
FATF High-Risk Jurisdiction — Call for Action. EDD mandatory under Reg. 33 MLR 2017. Senior management sign-off required before proceeding.
PEP identified. EDD mandatory under Reg. 35 MLR 2017. Senior management approval required. Document source of wealth with enhanced rigour.
Adverse media or sanctions match identified. Document findings, assess materiality, and consider EDD. Consider escalation to your MLRO before proceeding.
EDD required on this matter. One or more high-risk factors have been identified across your client(s). Enhanced Due Diligence must be fully documented before you proceed to exchange. Refer to your firm's EDD procedure and ensure senior management sign-off is obtained and recorded on the file.
Establish and document the origin of all funds used to complete this transaction. Every source must be identified, evidenced, and reconciled against the total funds required.
Multiple funding sources identified. Complex funding structures require thorough, source-by-source documentation. Ensure all sources are individually evidenced and their combined amounts reconcile against the total funds required to complete.
Overseas mortgage lender. An overseas lender may not be subject to AML regulation equivalent to UK standards. Document the lender's jurisdiction and regulated status, and assess the level of AML scrutiny applied. Standard UK lender reliance provisions under Reg. 39 MLR 2017 do not apply.
Gifted deposit requirements (LSAG Guidance s.4.4 & UK Finance Lenders' Handbook). Obtain a signed gift letter confirming the gift is non-repayable. Verify the donor's identity unless already verified as a client. Establish and evidence the donor's own source of funds. Notify the mortgage lender of any gift contribution before exchange.
Conditional or repayable gift — potential undisclosed loan. A conditional or repayable gift may constitute a loan that must be disclosed to the mortgage lender. Failure to disclose may give rise to a conflict of interest or a breach of the CML/UK Finance Lenders' Handbook. Consider whether you can continue to act for both buyer and lender. If doubt remains, report to your MLRO before proceeding.
Overseas-resident donor. Additional scrutiny is required. Verify the donor's identity using certified copies of documents, obtain overseas bank statements evidencing the gift amount, and establish the donor's source of wealth. Assess the donor's country of residence against FATF risk lists and apply enhanced scrutiny if the country appears on the grey or blacklist.
Cryptocurrency source — enhanced scrutiny required (LSAG Guidance s.4.7). Trace the complete chain from original acquisition through to fiat conversion. Obtain full exchange transaction histories, evidence of original acquisition (purchase records, mining income, or another verifiable origin), and confirm the exchange is regulated and applied its own AML/KYC checks. Peer-to-peer or untraced crypto is high risk and may require referral to your MLRO before proceeding.
Overseas funds — additional documentation required. Obtain bank statements or transfer records from the originating institution, confirm the institution's name and jurisdiction, and document the origin of those funds within the overseas account. Risk is further calibrated by the country of origin below.
Funds from a FATF increased monitoring jurisdiction. The country of origin is on the FATF Grey List. Enhanced scrutiny is recommended. Obtain comprehensive overseas bank statements and independent evidence of the original source within that jurisdiction, and document all steps taken.
Funds from a FATF high-risk jurisdiction — Call for Action. Accepting funds from this jurisdiction presents a very high AML risk. Enhanced Due Diligence is mandatory under Reg. 33 MLR 2017. Senior management approval is required before proceeding. Carefully consider whether accepting these funds is appropriate and document all measures applied in full.
Unexplained deposit(s) identified — do not proceed without resolution. A satisfactory explanation, supported by documentary evidence, must be obtained for each unexplained deposit before exchange. If a credible, evidenced explanation cannot be established, you must consider whether a Suspicious Activity Report (SAR) is required under s.330 POCA 2002 before continuing to act. Do not take any further steps that could constitute tipping off (s.333A POCA 2002).
Record identity verification details and screening results for each client. The plausibility assessment engine below generates targeted review prompts based on the matter profile you have built in earlier steps.
Reg. 39 Reliance — Written Agreement Required. You must obtain written confirmation that the third party is supervised under the MLRs, has applied the required CDD measures, and will provide CDD data promptly on request. Record the third party's name in the "Verified By" field below.
Address Discrepancy — Further Investigation Required. The address on the proof of address does not match the client's stated address. Obtain further documentary evidence to resolve the discrepancy and record your explanation before proceeding. Consider whether a CIFAS search is warranted.
Sanctions Match — Do Not Proceed. A confirmed or unresolved sanctions match requires immediate escalation to your MLRO. You must not proceed with this transaction. Providing services to a sanctioned party is a criminal offence. A SAR may be required under POCA 2002.
PEP / RCA Identified — Enhanced Due Diligence Required. Under Reg. 35 MLR 2017, PEPs and their relatives and close associates require EDD. Obtain senior management approval before establishing or continuing this business relationship and apply enhanced ongoing monitoring throughout the retainer.
Reg. 39 Reliance — Written Agreement Required. You must obtain written confirmation that the third party is supervised under the MLRs, has applied the required CDD measures, and will provide CDD data promptly on request. Record the third party's name in the "Verified By" field below.
Address Discrepancy — Further Investigation Required. The address on the proof of address does not match the client's stated address. Obtain further documentary evidence to resolve the discrepancy and record your explanation before proceeding. Consider whether a CIFAS search is warranted.
Sanctions Match — Do Not Proceed. A confirmed or unresolved sanctions match requires immediate escalation to your MLRO. You must not proceed with this transaction. Providing services to a sanctioned party is a criminal offence. A SAR may be required under POCA 2002.
PEP / RCA Identified — Enhanced Due Diligence Required. Under Reg. 35 MLR 2017, PEPs and their relatives and close associates require EDD. Obtain senior management approval before establishing or continuing this business relationship and apply enhanced ongoing monitoring throughout the retainer.
Reg. 39 Reliance — Written Agreement Required. You must obtain written confirmation that the third party is supervised under the MLRs, has applied the required CDD measures, and will provide CDD data promptly on request. Record the third party's name in the "Verified By" field below.
Address Discrepancy — Further Investigation Required. The address on the proof of address does not match the client's stated address. Obtain further documentary evidence to resolve the discrepancy and record your explanation before proceeding. Consider whether a CIFAS search is warranted.
Sanctions Match — Do Not Proceed. A confirmed or unresolved sanctions match requires immediate escalation to your MLRO. You must not proceed with this transaction. Providing services to a sanctioned party is a criminal offence. A SAR may be required under POCA 2002.
PEP / RCA Identified — Enhanced Due Diligence Required. Under Reg. 35 MLR 2017, PEPs and their relatives and close associates require EDD. Obtain senior management approval before establishing or continuing this business relationship and apply enhanced ongoing monitoring throughout the retainer.
Reg. 39 Reliance — Written Agreement Required. You must obtain written confirmation that the third party is supervised under the MLRs, has applied the required CDD measures, and will provide CDD data promptly on request. Record the third party's name in the "Verified By" field below.
Address Discrepancy — Further Investigation Required. The address on the proof of address does not match the client's stated address. Obtain further documentary evidence to resolve the discrepancy and record your explanation before proceeding. Consider whether a CIFAS search is warranted.
Sanctions Match — Do Not Proceed. A confirmed or unresolved sanctions match requires immediate escalation to your MLRO. You must not proceed with this transaction. Providing services to a sanctioned party is a criminal offence. A SAR may be required under POCA 2002.
PEP / RCA Identified — Enhanced Due Diligence Required. Under Reg. 35 MLR 2017, PEPs and their relatives and close associates require EDD. Obtain senior management approval before establishing or continuing this business relationship and apply enhanced ongoing monitoring throughout the retainer.
Prompts are based on matter details, client profile, and source of funds entered in the previous steps. Click Refresh prompts after making changes in earlier steps.
Generate a structured AI plausibility assessment for this matter using LÆdar. The output is editable — review and amend before finalising.
The risk score is automatically calculated from the matter profile built in earlier steps. Review each factor, complete your assessment narrative, and obtain MLRO sign-off where the risk rating requires it.
SAR / DAML — Tipping-Off Prohibition Applies. Under s.333A POCA 2002, you must not disclose to the client or any third party that a suspicious activity report has been or may be made. Do not use code words or hints. If a DAML consent application is made to the NCA, you must not proceed with the transaction until consent is received or the moratorium period expires without objection.
Risk Downgrade — Justification Required. The assessed risk level is lower than the calculated score indicates. Ensure your assessment narrative fully justifies this decision and that it has been reviewed by a senior fee earner or supervisor.
Declaration Required. You must tick the declaration checkbox and enter your typed full name before proceeding to final review and sign-off.