CDD · Risk Assessment · MLRO Decisions
Matter-by-matter AML compliance for law firms — structured client due diligence, risk assessment and documented MLRO decisions aligned to MLR 2017 and SRA guidance.
Enter firm details, matter type and client information. Covers all matter types from conveyancing to corporate transactions, wills, trusts and immigration.
Structured CDD, identity verification, source of funds assessment and sanctions screening — with LÆdar AI-assisted adjudication and documented plausibility assessments.
A complete, defensible MLRO decision record aligned to SRA and LSAG guidance — with clear risk rating and documented rationale. Print or export as PDF.
The workflow covers all matter types regulated under MLR 2017 — from property and corporate work to trusts, immigration and litigation.
Specific AML guidance for each matter type covered by MLR 2017. From property transactions to corporate deals, trust formations and immigration matters.
Step-by-step client due diligence covering identity verification, beneficial ownership, source of funds and PEP assessment — producing a complete audit-ready record.
AI-assisted sanctions, PEP and adverse media screening with structured plausibility assessments and false positive documentation for every subject screened.
A complete, defensible MLRO decision record in minutes. Aligned to MLR 2017 and SRA guidance, with clear risk rating and documented rationale. Print or export as PDF.
Access the LÆdar Law Firm AML Workflow.
Authorised KYCifi users only.
Request access: contact@kycifi.com
From client identification to documented risk decision — a structured AML workflow for law firms, matter by matter, powered by LÆdar.
Record the firm, MLRO, and matter reference details. This information appears on the completed AML file note and calibrates risk throughout the workflow.
No data is transmitted or stored. All information remains in your browser only. Use the print or export function at the final step to save the completed AML file note.
Residential Conveyancing selected. LSAG guidance requires enhanced scrutiny of source of funds for property transactions. Mortgage details and deposit sourcing will be captured in Step 3.
High-value matter (over £100,000). Enhanced due diligence and source of funds verification is required. Ensure supporting documentation is obtained and retained on file.
Record identifying details for each client on this matter. Nationality, country of residence, and screening status directly inform the risk rating at Step 5.
Enhanced Due Diligence Required
One or more clients on this matter require Enhanced Due Diligence. Mandatory triggers include: PEP status, FATF high-risk jurisdiction, or an adverse media / sanctions match. Senior management approval and enhanced SOF/SOW documentation are required before proceeding. Refer to Reg. 33–35 MLR 2017.
Non-UK resident client. Consider whether certified copies of identity documents are required. Ensure satisfactory proof of overseas address is obtained. Refer to SRA AML guidance on non-face-to-face CDD.
FATF increased monitoring jurisdiction. This country is on the FATF Grey List. Enhanced scrutiny is recommended under Reg. 33 MLR 2017. 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 and obtain senior management sign-off before proceeding.
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 funds must be documented with enhanced rigour.
RCA status confirmed. This person is a relative or close associate of a PEP. Enhanced Due Diligence applies under Reg. 35(1)(b) MLR 2017. Apply the same enhanced scrutiny as for a PEP and document senior management approval.
Adverse media or sanctions match identified. Document the nature and source of findings, assess materiality and relevance, 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. Ensure satisfactory proof of overseas address is obtained.
FATF increased monitoring jurisdiction. Enhanced scrutiny is recommended under Reg. 33 MLR 2017.
FATF High-Risk Jurisdiction — Call for Action. EDD is mandatory under Reg. 33 MLR 2017. Document all enhanced measures and obtain senior management sign-off.
PEP identified. EDD is mandatory under Reg. 35 MLR 2017. Senior management approval required.
RCA status confirmed. Apply EDD equivalent to a PEP. Document senior management approval. Reg. 35(1)(b) MLR 2017.
Adverse media or sanctions match identified. Document findings, assess materiality, and consider escalation to MLRO.
Non-UK resident client. Consider certified ID requirements and ensure proof of overseas address is obtained.
FATF increased monitoring jurisdiction. Enhanced scrutiny recommended under Reg. 33 MLR 2017.
FATF High-Risk Jurisdiction. EDD mandatory. Document all measures and obtain senior management sign-off.
PEP identified. EDD mandatory under Reg. 35 MLR 2017.
RCA confirmed. Apply EDD equivalent to a PEP. Reg. 35(1)(b) MLR 2017.
Adverse media or sanctions match. Document findings and consider escalation to MLRO.
Non-UK resident client. Consider certified ID requirements and ensure proof of overseas address is obtained.
FATF increased monitoring jurisdiction. Enhanced scrutiny recommended under Reg. 33 MLR 2017.
FATF High-Risk Jurisdiction. EDD mandatory. Document all measures and obtain senior management sign-off.
PEP identified. EDD mandatory under Reg. 35 MLR 2017.
RCA confirmed. Apply EDD equivalent to a PEP. Reg. 35(1)(b) MLR 2017.
Adverse media or sanctions match. Document findings and consider escalation to MLRO.
Document the origin of funds being used in this matter and the broader accumulated wealth of each client. Where Enhanced Due Diligence applies, detailed evidence must be obtained and retained on file.
MLR 2017 — Reg. 28 & Reg. 33. Firms must obtain information on the source of funds and, for higher-risk matters, source of wealth. Where a client is a PEP, comes from a high-risk third country, or the matter value is significant, enhanced verification is required. Documentation must be obtained and retained on file.
Gift or Loan identified. Where funds are provided as a gift or loan, the identity and source of funds of the donor or lender must be verified as a third party under MLR 2017 Reg. 28. Obtain a signed gift letter or loan agreement and retain on file.
Funds inconsistent with client profile. Enhanced due diligence is required. Obtain and retain supporting documentation evidencing the origin of funds. Consider whether a Suspicious Activity Report (SAR) is appropriate and consult the MLRO.
POCA 2002 — Reporting Obligation May Apply. Where unexplained transactions or fund inconsistencies give rise to a suspicion of money laundering, the firm must submit a Suspicious Activity Report (SAR) to the National Crime Agency before proceeding — POCA 2002 ss.330–332. You must not "tip off" the client (s.333A). Consult the MLRO immediately before taking any further steps on the matter.
Director Loan. Verify the source of funds of the lending director independently. The loan must be documented, arm's-length, and the director's own source of funds verified under MLR 2017 Reg. 28. Obtain a signed loan agreement and bank statements evidencing the director's funds.
Corporate Structure Chart Not Obtained. A structure chart is required to map the full beneficial ownership chain. Obtain before proceeding — MLR 2017 Reg. 28(3).
UBO Not Confirmed. The Ultimate Beneficial Owner must be identified and verified — MLR 2017 Reg. 28. Where no individual holds more than 25%, identify the senior managing official. Do not proceed until the UBO is confirmed.
Offshore Entity Identified. Offshore structures present heightened ML/TF risk. Verify the full beneficial ownership chain for each offshore entity. Obtain certified constitutional documents and UBO confirmation, and consider whether EDD is required — MLR 2017 Reg. 33.
Third-Party Funder. A funder who is not otherwise a client must have their identity and source of funds verified under MLR 2017 Reg. 28 before funds are accepted.
SPV / Special Purpose Vehicle. Acquisition through an SPV requires full beneficial ownership verification of the SPV. Identify and verify all shareholders and directors, and confirm whether the SPV has any prior trading history or liabilities — MLR 2017 Reg. 28(3).
Offshore Funds Identified. Funds from offshore accounts or entities require enhanced scrutiny. Verify with certified bank statements or audited accounts, and consider whether EDD is required — MLR 2017 Reg. 33.
Foreign Assets Identified. Consider CRS/FATCA reporting obligations, local disclosure requirements, and the heightened ML risk associated with offshore wealth. Obtain and retain documentary evidence of all foreign assets and accounts.
Discretionary Trust Structure. Identify and verify the settlor, all trustees, any protector, and the class of beneficiaries. Obtain a copy of the trust deed and confirm the source of the settled funds — MLR 2017 Reg. 28(10).
Beneficiary Identification Incomplete. All beneficiaries receiving a defined interest must be identified. Obtain verification before any distribution of funds — MLR 2017 Reg. 28.
Capacity / Undue Influence Concern. Escalate to the MLRO and seek a medical capacity assessment before proceeding. Consider whether a SAR is appropriate — POCA 2002 s.330.
Third-Party Payer. Verify the identity and source of funds of the third-party payer. Confirm their relationship to the applicant and obtain identification documents — MLR 2017 Reg. 28.
Investor / High-Value Immigration Matter. Enhanced Due Diligence is required. Verify the source of investment funds in full — obtain certified evidence of the investable capital (bank statements, audited accounts, business sale contracts) and conduct enhanced adverse media and sanctions screening — MLR 2017 Reg. 33.
Overseas / Offshore Assets. Consider enforcement jurisdiction, cross-border freezing orders, and HMRC disclosure obligations. Obtain asset schedules covering all overseas property, accounts, and investments.
Injunction or Freezing Order. Ensure the firm does not take any steps that could constitute contempt of court or assist in dissipation of frozen assets. Review the order and any carve-outs carefully before accepting funds or taking further instructions.
Financial Abuse / Economic Coercion. This may constitute a criminal offence under the Serious Crime Act 2015. Ensure the client receives independent advice. Where coercion is suspected, consider whether a SAR is appropriate and consult the MLRO — POCA 2002 s.330.
High-Value Claim. Claims over £250,000 present elevated financial crime risk. Ensure enhanced source of funds verification is completed and all funding arrangements are fully documented — MLR 2017 Reg. 33.
Cross-Border Element. Consider conflict of laws, enforcement jurisdiction, and whether any foreign counterparties are from FATF high-risk countries. Enhanced screening and documentation is required for all foreign parties.
Regulatory Overlap Identified. Where the matter involves an investigation by FCA, HMRC, SFO, or CMA, there is elevated financial crime risk. Do not take steps that could constitute obstruction or tipping off. Consult the MLRO before proceeding — POCA 2002 ss.333A–333D.
Asset-Tracing / Freezing Order. Strict compliance with the terms of any freezing injunction is required. Any dealing with frozen assets — including payment of legal fees — requires the court's permission. Review the order and any carve-outs carefully before accepting funds.
Whistleblowing / Protected Disclosure. The firm has specific confidentiality duties and must not disadvantage the discloser. Consider whether allegations in the disclosure give rise to a separate SAR obligation under POCA 2002 s.330. Consult the MLRO.
Record the identity documents obtained and verification method used for each client, along with the results of your sanctions, PEP, and adverse media screening. The Plausibility Assessment Engine will flag risk indicators for your review.
MLR 2017 — Reg. 28 Customer Due Diligence. Verify the identity of each client before establishing the business relationship. For individuals: a government-issued photo ID and proof of address. For entities: certificate of incorporation, constitutional documents, and identity of the beneficial owner and authorised representative.
Third-Party Reliance — Reg. 39 MLR 2017. You may rely on another regulated professional's CDD only if: (a) they are subject to equivalent AML obligations; and (b) you obtain written confirmation they have carried out appropriate CDD and will provide records on request. You retain full legal responsibility for the adequacy of the CDD performed.
Sanctions Match — Mandatory Referral. Do not proceed. A potential sanctions match must be investigated with the MLRO immediately. Acting for a sanctioned person or entity may be a criminal offence under the Sanctions and Anti-Money Laundering Act 2018. A SAR to the NCA may be required before consent to proceed can be obtained — POCA 2002 s.335.
PEP Match Identified by Screening. Enhanced Due Diligence is mandatory under MLR 2017 Reg. 35. Senior management approval is required before establishing or continuing this relationship. Enhanced source of funds and wealth documentation is required.
PEP Status Discrepancy. Screening has returned a PEP match, but the Client Profile (Step 2) records PEP status as "No." Investigate and reconcile before proceeding. Update the Client Profile if required.
Adverse Media Identified. Document the nature and source of the finding. Assess its materiality and relevance to the client's ML/TF risk profile. Consider whether escalation to the MLRO is required before proceeding.
Screening Not Conducted. A risk-based approach requires sanctions, PEP, and adverse media screening before proceeding. Document the justification for any omission and complete outstanding checks as a priority.
Document Discrepancy — Explanation Required. Minor discrepancies (e.g. name variations, middle name omissions, minor address differences) must be documented and explained on file. Ensure the explanation is plausible and that the client's identity has been verified to the required standard.
Major Discrepancy or Authenticity Concern. Do not proceed. Material inconsistencies or document authenticity concerns must be escalated to the MLRO immediately. Consider whether a SAR to the NCA is appropriate — POCA 2002 s.330.
Enhanced Due Diligence Required. Document all additional steps taken: enhanced SoF/SoW verification, enhanced ongoing monitoring, and senior management approval with rationale. Maintain a separate EDD file note — MLR 2017 Regs. 33–35.
CDD Deferred — Reg. 30 MLR 2017. CDD may only be deferred where it is necessary not to interrupt normal business and there is a low risk of ML/TF. Deferred CDD must be completed as soon as practicable. The matter must not proceed to completion before CDD is finalised. Document the justification on file.
MLRO Referral Required — Do Not Proceed. This matter must be referred to the MLRO before any further work is undertaken. Do not inform the client of the referral. The MLRO will determine whether a SAR to the NCA is required and whether consent to proceed can be given — POCA 2002 ss.330–332, 335.
Third-Party Reliance — Reg. 39 MLR 2017. You may rely on another regulated professional's CDD only if they are subject to equivalent AML obligations and you obtain written confirmation they have carried out appropriate CDD. You retain full legal responsibility.
Sanctions Match — Mandatory Referral. Do not proceed. Refer to MLRO immediately. A SAR may be required before consent to proceed can be obtained — POCA 2002 s.335.
PEP Match. EDD is mandatory — Reg. 35 MLR 2017. Senior management approval required before establishing or continuing this relationship.
PEP Status Discrepancy. Screening returned a PEP match but Step 2 records PEP as "No." Investigate and reconcile before proceeding.
Adverse Media Identified. Document the nature and source of the finding and assess materiality. Consider escalation to the MLRO.
Screening Not Conducted. Complete outstanding screening checks as a priority and document any risk-based justification for deferral.
Discrepancy — Explanation Required. Document and explain any minor discrepancies on file to the required standard.
Major Discrepancy or Authenticity Concern. Do not proceed. Escalate to MLRO immediately — POCA 2002 s.330.
EDD Required. Document enhanced SoF/SoW verification, ongoing monitoring, and senior management approval — MLR 2017 Regs. 33–35.
CDD Deferred — Reg. 30. Complete CDD as soon as practicable. The matter must not proceed to completion before CDD is finalised. Document the justification on file.
MLRO Referral Required. Do not proceed or tip off the client. The MLRO will determine whether a SAR is required — POCA 2002 ss.330–332, 335.
Third-Party Reliance — Reg. 39. Obtain written confirmation of CDD from the regulated third party. You retain full legal responsibility.
Sanctions Match. Do not proceed. Refer to MLRO — POCA 2002 s.335.
PEP Match. EDD mandatory — Reg. 35 MLR 2017. Senior management approval required.
PEP Discrepancy. Screening found a PEP match but Step 2 records PEP as "No." Reconcile before proceeding.
Adverse Media. Document findings and assess materiality. Consider MLRO escalation.
Screening Not Conducted. Complete outstanding checks and document any justification for deferral.
Minor Discrepancy. Document and explain on file.
Major Discrepancy or Authenticity Concern. Do not proceed. Escalate to MLRO — POCA 2002 s.330.
EDD Required. Document enhanced measures and senior management approval — Regs. 33–35.
CDD Deferred — Reg. 30. Complete CDD as soon as practicable and before matter completion.
MLRO Referral Required. Do not proceed — POCA 2002 ss.330–332, 335.
Third-Party Reliance — Reg. 39. Obtain written confirmation of CDD. You retain full legal responsibility.
Sanctions Match. Do not proceed. Refer to MLRO — POCA 2002 s.335.
PEP Match. EDD mandatory — Reg. 35 MLR 2017. Senior management approval required.
PEP Discrepancy. Screening found a PEP match but Step 2 records PEP as "No." Reconcile before proceeding.
Adverse Media. Document and assess materiality. Consider MLRO escalation.
Screening Not Conducted. Complete outstanding checks and document justification for any deferral.
Minor Discrepancy. Document and explain on file.
Major Discrepancy or Authenticity Concern. Do not proceed. Escalate to MLRO — POCA 2002 s.330.
EDD Required. Document enhanced measures and senior management approval — Regs. 33–35.
CDD Deferred — Reg. 30. Complete before matter completion and document justification.
MLRO Referral Required. Do not proceed — POCA 2002 ss.330–332, 335.
The risk score below is automatically calculated from client profiles, source of funds indicators, and identity and screening results recorded in the preceding steps. Review each contributing factor, record your overall risk assessment, and complete the fee earner declaration.
Enhanced Due Diligence Required. Obtain enhanced source of funds and source of wealth documentation. Apply enhanced ongoing monitoring and obtain senior management approval before proceeding. Record all additional measures taken in the narrative below and maintain a separate EDD file note — MLR 2017 Regs. 33–35.
Tipping Off — Strict Prohibition (POCA 2002 s.333A). Do not inform the client, any third party, or any other person that a referral has been made to the MLRO or that a Suspicious Activity Report may be submitted to the NCA. Tipping off is a criminal offence punishable by up to five years’ imprisonment. Cease all substantive work on the matter immediately until the MLRO gives consent to proceed.
DAML / Consent under POCA 2002 s.335. If the MLRO determines that a SAR is required, a Suspicious Activity Report in Defence Against Money Laundering (DAML) form must be submitted to the NCA before any prohibited act is carried out. The NCA has 7 working days to respond. Do not proceed, complete the matter, or receive any funds until a “no objection” notice is received or the moratorium period expires without objection. Failure to obtain consent before acting is a criminal offence under POCA 2002 s.328.
Review the complete AML due diligence record below. When satisfied that all information is accurate and complete, download the PDF Decision Record to retain on the client file in accordance with MLR 2017 Regulation 40 (minimum five years from the end of the business relationship).
Loading summary…