Warners Solicitors LLP: AML Statement of Intent

Warners Solicitors LLP is a limited liability partnership registered in Scotland. Our registered office is at: 22, St. Patrick Square, Edinburgh, EH8 9EY.

Warners is regulated by The Law Society of Scotland, registration number is 33172.

 

1. Statement

It is the policy of Warners Solicitors LLP ("Warners") to comply fully with applicable provisions of the Proceeds of Crime Act 2002, Terrorism Act 2000 and The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and all amending legislation.

 

2. Purpose

2.1 The purpose of this policy is to ensure Warners' compliance with UK Anti‐Money Laundering laws and regulations, to assist law enforcement in combating illegal money laundering and to minimise the risk of Warners being used for illicit purposes by having in place robust and effective procedures to implement our AML Policy.

2.2 By definition, money laundering is the practice of cleaning up money that has, for some reason, been obtained illegally. Often there is a complex trail involved so that the practice cannot be easily identified or traced.

2.3 Money laundering can occur in many ways. It may happen by dispersing money through many different bank accounts (to hide its origins) but can also occur when Warners is used unwittingly by clients or third parties for illegal activities.

 

3. Procedures

3.1 Douglas Williamson is the Nominated Money Laundering Reporting Officer (MLRO) to receive disclosures from anyone involved in Warners of any suspected money laundering activities.

3.2 The MLRO is responsible for carrying out Warners' Anti‐Money Laundering procedures and will issue detailed guidelines to all Warners staff on procedures at regular intervals.

3.3 The MLRO will carry out at regular intervals a firm wide risk assessment based on the nature and sources of the business carried out by Warners and its client overall database and ensure that all Warners staff are carrying out appropriate Customer Due Diligence and risk-based assessments of all business carried out by Warners. 

3.4 The MLRO and Deputy MLRO will carry out and record training provided to all staff, either in groups or on a One to One basis.

3.5 The MLRO will ensure that proper records are maintained on all the relevant activities and steps taken to deal with them, and in relation to training.

 

4. Customer Due Diligence

4.1 Warners will carry out procedures that help it identify customers/clients before accepting or entering into a relationship or transaction with them.

4.2 Warners will, where applicable:

4.2.1 Identify the Client, Associated persons and verify their identity;

4.2.2 Take adequate measures to risk assess all business transacted by / for clients;

4.2.3 Continuously monitor the situation; and

4.2.4 Maintain proper records of all checks made.

 

5. Policy on disclosure

5.1 If anyone knows, suspects or has reasonable grounds for thinking or suspecting that a person involved with Warners, whether as a client or a third party, is engaged in money laundering or terrorist financing, they must report such matters to the MLRO (Douglas Williamson) immediately. The MLRO can be contacted on can be contacted at 0131 668 0439 / sps@warnersllp.com. Further details on procedures for internal reporting are provided to staff of Warners for internal Anti Money Laundering and Proceeds of Crime Procedures guide.

5.2 It is the policy of Warners to make disclosure to the relevant authorities if it has any cause to suspect that Money Laundering or any other crime has been committed, in line with Law Society Scotland and POCA 2002.