AML compliance isn’t about filling in forms and filing them away. It’s about understanding who your client is, what risk they present, and why your firm decided to proceed. Templates can create structure, but they can also give a false sense of security if they replace proper judgement. As Tranche 2 approaches, law firms need AML programmes that work in practice with clear thinking, consistent decision-making and evidence that shows not just what was done, but why.

Siloed teams in law firms create hidden AML risks. Without shared intelligence across departments, suspicious patterns can go undetected.