This Practice Note is intended for law firms that are subject to the Money laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended. It provides guidance on the requirement to appoint a board-level (or equivalent) person as the Officer responsible for the firm’s Compliance with the MLR 2017. This position is commonly known as the money laundering compliance officer (MLCO) or board-level person.

Not all firms are required to appoint an MLCO. Sole practitioners are not required to do so and other firms are only required to appoint an MLCO where:

1. •

   they are caught by the MLR 2017, and

2. •

   it is appropriate to appoint an individual having regard to the size and nature of the business

Where the firm does appoint an MLCO, see Precedents: MLCO and nominated officer—combined job description and role profile—law firms or Money laundering compliance officer—MLCO—job description and role profile—law firms.

This Practice Note reflects the Legal Sector Affinity Group (LSAG) AML guidance.

This Practice Note also reflects key