Anti-money laundering compliance is one of the biggest sources of regulatory anxiety for Scottish law firms — and the rules just changed again. Here is a practical checklist to keep your firm on the right side of them.
The Law Society of Scotland's 2026 Sectoral Risk Assessment confirms that the Scottish legal sector continues to face a high inherent risk of money laundering. With HM Treasury and the National Crime Agency classing the legal sector as high risk, and the Law Society itself supervised by OPBAS, AML is an area where firms simply cannot afford to be complacent. This checklist walks through the essentials.
The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 came into force on 30 June 2026, updating the 2017 Regulations. Changes include narrowed enhanced due diligence triggers (now focused on FATF "Call for Action" jurisdictions), a revised "unusually large or unusually complex" transactions test, euro thresholds converted to sterling, and the sale of an "off-the-shelf firm" brought into scope. Firms should review their risk assessments, policies and training to reflect these.
Your practical AML checklist
1. Keep your risk assessments current
The foundation of AML compliance is a documented, up-to-date Practice-Wide Risk Assessment, supported by client-level and matter-level risk assessments. The Law Society provides templates for all three. Make sure yours reflect the June 2026 changes rather than sitting untouched from a previous year.
2. Maintain robust policies, controls and procedures
Your firm needs written Policies, Controls and Procedures (PCPs) that translate the regulations into day-to-day practice — covering customer due diligence, enhanced due diligence, ongoing monitoring, record-keeping and reporting.
3. Get customer due diligence right, every time
Verify client identity, understand the purpose of the retainer, and identify beneficial owners where relevant. Apply enhanced due diligence where the regulations require it — including matters connected to FATF Call for Action jurisdictions, or transactions that are unusually large or unusually complex in the context of the client and matter.
4. Scrutinise source of funds
Establishing where client money genuinely comes from is one of the most important — and most scrutinised — parts of the process, particularly in conveyancing and other transactional work. Build source-of-funds checks into your standard workflow rather than treating them as an afterthought.
5. Appoint and support your MLRO
Your Money Laundering Reporting Officer is central to compliance, handling internal reports and, where appropriate, Suspicious Activity Reports. Make sure they have the authority, time and training to do the role properly.
6. Train your people — and keep records
Everyone in scope needs regular, documented AML training so they can recognise red flags and know how to escalate concerns. Training records are themselves part of demonstrating compliance.
Under Accounts Rule B9, completion of the Law Society of Scotland's annual AML Certificate is compulsory for all firms in scope of the 2017 Regulations. For 2026 the certificate was streamlined and its submission window moved to May–June. Missing it can lead to a complaint being referred to the Scottish Legal Complaints Commission.
How software helps
Good practice management software turns AML from a paperwork burden into a manageable, repeatable process — supporting client and matter risk assessments, structured ID verification and onboarding, source-of-funds records, and a clear audit trail. Some Scottish-focused platforms include a dedicated AML or compliance centre and biometric onboarding, which is exactly the kind of built-in support that makes consistent compliance far easier.
Denovo — built for Scottish firms
Denovo is our top-ranked platform for Scottish law firms, combining CaseLoad practice management, integrated legal accounts, the LawY AI assistant and optional outsourced cashroom services in one Scotland-specific system.
See the full comparisonThe bottom line
AML compliance is not a box-ticking exercise — it is a core professional obligation backed by an active supervisory regime. Keep your risk assessments and policies current with the June 2026 changes, embed due diligence and source-of-funds checks into everyday workflows, train your team, and submit your AML Certificate on time. The right software makes every one of those steps easier to do consistently.