The recently published Council for Licensed Conveyancers’ (CLC) 2025 Risk Agenda reinforces the desire for Anti-Money Laundering (AML) to become more than a tick-box exercise.
Instead, the CLC urges firms to embed AML as part of their cultural DNA. Its new framework of six ethical principles outlines this approach, urging conveyancers to go beyond the minimum compliance to protect the profession, the market, and clients from financial crime.
The aim is to highlight that AML is no longer just about satisfying auditors, it’s about safeguarding the integrity of property transactions and maintaining client trust. But how can already under-pressure firms and professionals make this shift from process to culture?
Going beyond bank statements
A simple mindset change is that a bank statement or ‘proof of funds’ is a sufficient check. The CLC’s guidance stresses that such basic steps are no longer enough. To really understand whether money entering a transaction is legitimate, conveyancers need to examine both the Source of Funds (SoF) and the Source of Wealth (SoW) to understand how and when the money was generated.
This means asking the right questions, joining the dots, and challenging inconsistencies. Those who build curiosity and thoroughness into their culture are far more likely to detect suspicious patterns before they become problems. With a lot of the areas discussed here, there’s tech around to do most of the time-consuming, heavy lifting, but the decision still needs to be made by the ultimate expert, the conveyancer.
AML as a living process
Another common shortfall highlighted in the Risk Agenda is the tendency to treat AML checks as a one-off hurdle at the start of a transaction. In reality, risks evolve. A client’s circumstances may shift, new parties may be introduced, or unusual payment routes may appear mid-way through a deal.
Thinking about AML as a continuous process, not a one-time task, is an important cultural change. Firms that refresh checks at key stages of the transaction will be better positioned to catch red flags. This requires systems that allow for easy recording, updating and reviewing of AML information, as well as staff who feel empowered to act on concerns without fear of delaying completions.
Timely and reliable information
Speed is critical in conveyancing, making robust checks tricky to manage. The CLC advises firms to prioritise early collection of information, ensuring that all documents are gathered, verified, and logged as soon as possible.
Doing this consistently avoids last-minute scrambles, prevents transaction delays and ensures decisions are made on sound evidence rather than assumptions. A culture of documenting every step also strengthens a firm’s ability to demonstrate compliance during audits.
Putting ethics at the core
Perhaps the most significant development in the 2025 Risk Agenda is the alignment of AML obligations with the CLC’s six new ethical principles:
- Act with integrity, honesty, and independence
- Know your client, treat them fairly, and act in their best interests
- Uphold the rule of law and public trust.
- Maintain high standards of professional and personal conduct
- Collaborate openly and truthfully with regulators, ombudsmen, and other legal professionals
- Promote equality, diversity, and inclusion in practice and service delivery
These principles encourage firms to view AML not as a regulatory requirement, but as a moral duty that protects clients, communities, and the wider economy.
Building ongoing competence
AML is not static. Criminals adapt, technologies evolve, and risks shift with global events. It is increasingly difficult to rely on outdated training or annual refresher sessions.
Regular workshops, reflective practice sessions, and scenario-based training help staff recognise real-world warning signs. These will help embed AML thinking into the everyday work culture.
Data-led prevention
The CLC also highlights the importance of data in shaping proactive risk prevention. By analysing patterns in transactions, reviewing outcomes of previous inspections, and monitoring where issues most frequently occur, firms can identify weak spots before they become systemic risks. Some conveyancers are already using tech tools and data to help spot emerging threats.
Shifting from burden to culture
The property sector has always been vulnerable to exploitation by those seeking to launder illicit funds. Regulators, lenders, and law enforcement will continue to raise the bar. But for conveyancers, the challenge is not just compliance, it’s building a workplace where AML is part of the professional identity and finding the time in the day to make it happen.
As a positive, conveyancers who embed AML as a cultural mindset can reduce their risk exposure, strengthen client trust, and build reputations that stand out in a competitive market.
Tom Lyes is Head of Legal and Property Services at Armalytix
2 responses
This is a prime example of where we are going wrong and the Conveyancing process in becoming increasingly bogged down. I fully agree with the ‘Ethical Principles’ we need to be aware of fraud but I am a Conveyancer, I am not a financial auditor. We have got to the point where it can take longer to review, assess and unravel a client’s financial trail than it takes to carry out the Conveyancing on a straight forward freehold terrace house.
By the time clients get to us they have often already had to prove themselves to the Estate Agent and Lender who also require ID checks and evidence of funds, there is no collaboration. Why are clients having to pay for an ID check with an estate agent and again with their Conveyancer?
The AML work needs to be separated out, there needs to be a separate specialist entity so when a purchaser has an offer accepted the first process is for them to complete an ID check and have their source of funds and source of wealth verified. Once ‘Passed’ an appropriate level report can be shared with agents, lenders and the Conveyancer.
We need to be finding ways to streamline the Conveyancing process, not simply place this burden fully onto the Conveyancer.
The essential issue is that the emphasis on AML Source of Funds and Source of Wealth fails to adequately reflect the Regulations and the requirement to undertake a risk assessment.
Thereafter the question is:how was the money accumulated?
And
Does the image created by the examination of documents and conversations with the client make sense?
What would assist Conveyancers would be reading the Regulations.
Starting work on a matter before completing the risk assessment is a breach of the Regulations unless you have a good reason.
And what format should the risk assessment take?
That depends on your Firm Wide Risk Assessment and understanding of your client base and transactions you normally undertake.
I wouldn’t rely on estate agents to have undertaken AML checks nor would I rely upon the lender.
Solicitors and Licensed Conveyancers are required to undertake the AML Risk Assessment primarily because no one else can be trusted to do it properly. It shouldn’t be our responsibility but it is.
So assess the risk: how likely is it we are unwittingly assisting in the legitimisation of money obtained illegally?
What do we know about the client?
What third parties are involved and what do we know about them?
How has the money from client, giftors and in bank accounts to be used to fund the transaction been accumulated?
Does this feel right?