Particular care is required whenever funds are received into or paid from the Firm's Client Account. The legal sector is recognised as being vulnerable to exploitation by criminals seeking to disguise, move or legitimise funds.
Client accounts may be attractive because they offer:
The movement of funds through the Client Account does not, by itself, demonstrate legitimacy. Lawyers must therefore ensure they understand both the purpose of the transaction and the funds involved. Where funds are proposed to be received into the Client Account, the responsible lawyer must obtain and review evidence appropriate to the risk before payment unless the MLRO expressly approves a documented exception.