AML/CTF in Practice: Suspicious Matter Reports, Tipping Off & Practical Compliance

AML/CTF obligations require lawyers and legal staff to identify and report suspicious activity while taking care not to disclose information that could amount to tipping off. These obligations can arise in dealings with new or existing clients and related parties, creating practical challenges for practitioners managing ongoing matters. 

This practical seminar will focus on recognising when conduct may give rise to an SMR obligation, assessing the circumstances before making a report, and managing confidentiality and tipping-off risks. It will also consider common practical issues lawyers face when dealing with suspicious transactions, clients and investigations. 

This seminar will discuss: 

• AML/CTF reporting framework: Understand the key reporting obligations.  
• When an SMR is required: Identifying when reporting obligations arise.  
• Reasonable grounds for suspicion: Apply the test to practical circumstances.  
• Identifying & assessing suspicious activity: Practical approaches to identifying and assessing potential red flags. 
• SMR reporting timeframes: Key deadlines and reporting requirements. 
• Drafting effective SMRs: Key considerations for accurate reporting. 
• Enhanced customer due diligence: Managing ongoing AML/CTF risk. 
• Ending customer relationships: Navigating customer exits and compliance considerations. 
• Tipping off: Identify prohibited disclosures and potential consequences.  
• Permitted disclosures: Understand when disclosure is permitted.