DIA’s enforcement history shows that AML/CFT breaches in the legal sector are not hypothetical. Foster & Milroy, Kidd Legal and PSB each provide a clear reminder that law firms must be able to show more than AML/CFT documents. They must be able to evidence that their risk assessment and compliance programme are current, understood, followed and working in practice.

A Hamilton law firm’s $60,000 AML/CFT fine carries a wider warning for the legal sector. The Foster & Milroy case is a reminder that AML/CFT compliance must be current, evidenced and operating in practice, not just sitting on paper.