UK: CRIMINAL RECORD CHECKING AND DISCLOSURES REQUIRED UNDER AML REGULATIONS AFFECTED BY COVID-19

On 30 April, the Law Society of Scotland highlighted that because Disclosure Scotland was having to prioritise criminal records checks for people working on sectors deemed vital at this time (e.g. healthcare, pharmaceutical,  childcare and social work), legal firms are therefore currently unable to fulfil the criminal record checking and disclosures required of them by the money laundering regulations.  It says that it has highlighted this issue to HM Treasury, and it is said to be content that, on a temporary basis while Disclosure Scotland are operating under these restrictions, firms or new sole practitioners can provide a statutory declaration that the persons involved do not have a relevant criminal conviction as part of the application.  Checks must then be sought as soon as reasonably practicable once Disclosure Scotland are able to process applications.

https://www.lawscot.org.uk/news-and-events/law-society-news/money-laundering-registration-requirements-during-c19/

 

 

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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