The AML Clinic Podcast

Send us Fan Mail

Client accounts are one of the legal sector’s most significant money laundering risks.

In this episode, Michelle is joined by Dr Katie Benson, Senior Lecturer in Criminology at the University of Manchester, whose research on client account misuse is some of the most practically relevant academic work available to the legal sector. Together they explore how facilitation happens, what opportunity structures reveal about where the real vulnerabilities sit, and what the patterns in criminal convictions and regulatory enforcement cases tell us about where oversight breaks down.

Below are Katie’s 2024 and 2026 research papers co-authored by Bociga Gelvez

• “Occupation, Organisation, Opportunity, and Oversight: Law Firm Client Accounts and (Anti-)Money Laundering” (2024)
• “Complementarity, tension and proportionality in the anti-money laundering regulation of law firm client accounts” (2026)

Katie's book - Lawyers and the Proceeds of Crime

Send us Fan Mail

In this episode, Michelle Clement speaks with Nick Dale, Director of Intelligence and Prevention at Stop the Traffik, about how data, financial intelligence and pattern recognition can help expose trafficking and exploitation networks. He explains how seemingly insignificant pieces of information become significant when viewed in context and why the quality of a suspicious activity report can make a real difference.

For compliance professionals, this conversation offers a different perspective on the purpose behind the work.

Find out more about Stop the Traffik's work at www.stopthetraffik.org.

Send us Fan Mail

What is it really like to be an MLRO?

In this episode of The AML Clinic Podcast, Michelle Clement sits down with an experienced MLRO for an honest conversation about the realities behind one of the most demanding roles in AML compliance.

Together, they explore the judgement calls, competing pressures and accountability that come with the role, and why much of that responsibility often goes unseen.

Whether you're an MLRO, compliance professional, partner or member of a risk team, this episode offers a candid insight into the human side of AML compliance and the factors that support sound, defensible decision-making.

This episode also marks the conclusion of the first season of The AML Clinic Podcast. Thank you for listening, and we'll be back in the autumn with more conversations on AML, regulation and the practical realities of compliance.

Send us Fan Mail

Michelle Clement is joined by Suzie Ogilvie to discuss how firms can recognise and manage sanctions risk in practice, apply the "reasonable cause to suspect" threshold, and make defensible decisions that stand up to regulatory scrutiny.

Send us Fan Mail

Sovereign wealth funds and state-linked structures are often perceived as low risk because they carry an assumption of legitimacy. But how should firms assess these relationships in practice?

In this episode, Michelle Clement is joined by Colin Solomon to explore the lessons arising from the Jersey v LGL Trustees Ltd re Angola case, and what it reveals about risk classification, onboarding assumptions, professional judgement, and regulatory scrutiny.

Together, they discuss how perceptions of legitimacy can influence decision-making, what regulators look for when reviewing files in hindsight, and how firms can ensure their risk assessments and rationale stand up to scrutiny.

Colin has also prepared a summary of the case and regulatory findings. If you would like a copy, you can connect with him on LinkedIn: https://www.linkedin.com/in/colin-solomon-07102613/.

Send us Fan Mail

This episode explores the critical differences between having risk assessments and actively using them in law firms. Hosted by Michelle Clement, with AML consultant Kayleigh Smale, it emphasises how effective risk assessments can shape decision-making, influence behaviour, and ensure compliance.

This conversation is about what risk assessments are meant to evidence and why that’s harder than it looks.

Send us Fan Mail

In this episode of The AML Clinic Podcast, Michelle Clement is joined by Arik Oslerne to explore one of the biggest shifts currently shaping AML and client onboarding: the rise of AI.

The episode explores:

• where AI is currently adding practical value in AML and onboarding
• how automation is changing legal workflows and decision-making
• the risks of over-reliance, false confidence, and loss of context
• why AI outputs still require human challenge and interpretation
• what makes AI-supported decisions defensible under regulatory scrutiny
• how firms should think about oversight, audit trails, and accountability
• where the legal market is heading as firms increasingly embed AI into practice

The conversation focuses on the reality that regulators will still expect firms to explain how decisions were reached, what information was considered, and whether the outcome made sense in context.

Designed for law firm leaders, MLROs, compliance professionals, and risk teams, this episode offers a practical and grounded discussion on how firms can integrate AI into AML processes in a way that is effective, proportionate, and defensible.

SRA | Compliance tips for solicitors regarding the use of AI and technology | Solicitors Regulation Authority

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement, a former SRA AML Regulatory Manager, explores the often-overlooked aspect of recruitment in the context of AML compliance. Joined by Lauren Eager, a principal consultant at QED Legal, they discuss how hiring decisions reflect a firm's operational priorities, investment in compliance, and response to regulatory pressures. The conversation highlights the divide between firms that proactively build compliance teams and those that react only under pressure.

Send us Fan Mail

In this concluding episode of a three-part series, The AML Clinic Podcast brings together the core themes explored across the trilogy: how the SRA assesses seriousness, what it looks for in AML file reviews, and how internal decision-making shapes regulatory outcomes.

Michelle Clement (former SRA AML Regulatory Manager) focuses on where outcomes are truly determined in practice, at the point where risk is interpreted and judgement is applied.

Grounded in real-world environments, this episode explores:

• how risk is interpreted under pressure
• why consistency remains difficult across firms
• where technically complete files fall short
• what supports defensible decision-making

Designed for partners, MLROs, MLCOs and compliance professionals, this final instalment offers a clear view of what determines whether your AML approach stands up to scrutiny.

Send us Fan Mail

In this episode, former SRA AML Regulatory Manager Michelle Clement explains what the SRA actually looks for when reviewing your files, why technically complete files often fall short, and how to ensure your approach stands up to scrutiny.

Send us Fan Mail

In this episode of the AML Clinic Podcast, Michelle Clement explores how the SRA determines whether a breach is “serious” in practice.

Understanding how to evaluate the seriousness of breaches is essential for law firms. Many firms grasp the rules, but fewer truly understand how the SRA assesses seriousness. Knowing this can help you make defensible decisions and avoid unnecessary panic when issues arise.

Send us Fan Mail

In this episode, the tables are turned as I’m interviewed by Pearl Moses, the Former Head of Risk and Compliance at the Law Society who came prepared with questions gathered from AML professionals across the legal sector.

We discuss the biggest AML mistakes many law firms make, what ''does it make sense” means in practice, and how firms can challenge factual inaccuracies or misinterpretations during SRA engagement.

We also explore what the SRA looks for when reviewing files, what the FCA's take over means for the legal sector today, and why firms should focus on building defensible AML frameworks that stand up to scrutiny.

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement engages with Colin Solomon, a senior specialist in offshore financial services, to explore the complexities surrounding offshore jurisdictions and their associated AML risks.

The conversation delves into why offshore entities are deemed inherently risky, emphasising the need for a nuanced understanding of risk that transcends simplistic categorisations. Solomon argues that while there are bad actors in offshore jurisdictions, the perception of risk is often influenced by regulatory caution and media narratives. He provides practical insights for law firms on how to assess offshore structures and beneficial ownership, advocating for a risk-based approach that prioritizes understanding over assumptions.

Send us Fan Mail

What would it mean for law firms if AML supervision shifted from the SRA to the FCA? And what can the legal sector learn from financial services right now?

In this episode of The AML Clinic Podcast, Michelle is joined by Chantelle Obatolu, Financial Crime Specialist and Assistant Vice President in AML at Sumitomo Mitsui Banking Corporation. With extensive experience across global banks and consulting firms, Chantelle shares practical insight into how the FCA approaches AML supervision in practice.

They discuss:

• The FCA’s supervisory style and what reviews look like in reality
• How deep the FCA goes into governance, systems, culture, and files
• AML reporting expectations and how data drives supervision
• Senior accountability under the SMCR
• What effective remediation looks like
• What law firms can do now to be “FCA-ready”

Whether or not formal change happens, expectations around accountability, evidence, and risk management are rising. This episode offers clear, practical lessons for MLROs, compliance leaders, and law firm decision-makers navigating an evolving regulatory landscape.

Tune in to stay informed, stay compliant, and stay ahead.

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement and guest Ray Blake delve into the complexities of onboarding a corporate client within the framework of anti-money laundering (AML) compliance. They explore the critical distinctions between identifying and verifying corporate clients, the role of Special Purpose Vehicles (SPVs), and the importance of understanding ownership structures. The conversation highlights the red flags associated with SPVs, the limitations of relying solely on Companies House for verification, and the regulatory requirements for directors.

The episode concludes with practical advice for firms navigating due diligence processes, emphasising the need for thorough documentation and understanding of the regulatory landscape.

Send us Fan Mail

In this episode of The AML Clinic Podcast, Michelle Clement speaks with Christian Hunt, author of Human Risk, about why compliance failures in law firms are rarely caused by bad individuals and are more often the result of poorly designed systems.

They explore how behavioural science can improve AML and compliance outcomes, why traditional approaches like policies and training often fail, and how firms can better engage legal professionals in day-to-day compliance decision-making.

A practical conversation for AML, compliance and risk professionals working in or with law firms.

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement interviews Luke Haddon, the money laundering reporting officer at Keystone Law. They discuss Luke's career path, the proposed changes to the UK's money laundering regulations, and the implications of these changes for law firms. Luke expresses concerns about the introduction of pooled client accounts and emphasizes the importance of a risk-based approach to compliance. He also highlights the need for a collaborative culture between compliance teams and legal practitioners to ensure effective compliance and protect clients' interests.

Send us Fan Mail

In this episode of the AML Clinic Podcast, Michelle Clement and Eloise Butterworth discuss the evolving legislative landscape for law firms, focusing on AML compliance, resourcing hurdles, and the role of technology. Eloise shares her journey from family law to risk and compliance, emphasising the importance of clarity, training, and culture in managing AML obligations. They also explore the financial viability of law firms while meeting compliance standards and bust common myths about AML practices.

Links referenced

SRA annual report -solicitors-regulation-authority-limited-financial-statements-2024.pdf

SRA training checklist - aml-training-checklist.pdf

SRA | Sole practitioners' and small firms' use of technology and innovation | Solicitors Regulation Authority

See Customer due diligence section - SRA | Compliance with the regulations and preventing money laundering Q&A | Solicitors Regulation Authority

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation also covers the concept of criminal property, the Spanish bullfighter exception, and the balance between confidentiality and reporting obligations.

Takeaways

• Verifying source of funds in transactional and non transactional matters.
• The role of the MLRO in anti-money laundering compliance.
• Learn about the concept of criminal property under POCA.
• Explore the Spanish bullfighter exception in legal contexts.
• Balance confidentiality with reporting obligations in legal practice.
• Identify the challenges of anti-money laundering compliance.
• Discuss the principle of fungibility in financial transactions.
• Examine the role of legal professional privilege in reporting.
• Highlight the need for ongoing training in compliance.

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation also covers the concept of criminal property, the Spanish bullfighter exception, and the balance between confidentiality and reporting obligations.

Takeaways

• Verifying source of funds in transactional and non transactional matters.
• The role of the MLRO in anti-money laundering compliance.
• Learn about the concept of criminal property under POCA.
• Explore the Spanish bullfighter exception in legal contexts.
• Balance confidentiality with reporting obligations in legal practice.
• Identify the challenges of anti-money laundering compliance.
• Discuss the principle of fungibility in financial transactions.
• Examine the role of legal professional privilege in reporting.
• Highlight the need for ongoing training in compliance.

Spanish Bullfighter LSAG reference

https://www.sra.org.uk/globalassets/documents/solicitors/firm-based-authorisation/lsag-aml-guidance.pdf#=page193

Send us Fan Mail

In this episode of the AML Clinic, Michelle Clement and Graham Mackenzie discuss the critical issue of money laundering in law firms. They explore the vulnerabilities within legal services, particularly in conveyancing, the role of trust and company service providers (TCSPs), and the implications of tax advice. The conversation also addresses the risks associated with probate and busts the myth that firms without client accounts are not at risk of being used for money laundering. The episode emphasizes the importance of understanding the source of funds and the impact of legal work on local communities.

Send us Fan Mail

In this episode of the AML Clinic podcast, host Michelle Clement interviews Christopher Christou, a solicitor who shares his experiences with SRA AML inspections. The conversation covers the emotional journey of receiving an inspection notice, the preparation involved, and the importance of compliance in law firms. Christopher discusses the challenges of running a small firm, the role of technology in compliance, and the need for a culture of compliance within teams. The episode concludes with myth-busting in AML compliance, emphasising the importance of diligence and awareness in the legal profession.

Links

SRA | Guidance on our firm inspections | Solicitors Regulation Authority

SRA | Sole practitioners' and small firms' use of technology and innovation | Solicitors Regulation Authority

Send us Fan Mail

In this episode of The ANL Clinic, we dive into one of the most critical and often misunderstood areas of financial crime prevention: the difference between source of funds and source of wealth.

We explore a real Solicitor Disciplinary Tribunal case involving a politically exposed person, a £1.1 million transaction and a £1.9million transaction, and serious gaps in due diligence.

Key takeaways:

• Why distinguishing source of funds vs source of wealth matters
• The risks of relying on third-party assurances
• How compliance failures can lead to disciplinary action

SRA | Thematic review of source of funds and wealth compliance | Solicitors Regulation Authority