FINTRAC warns of lawyers’ AML risks, UK Companies House publishes intelligence assessment, Singapore announces new AML strategy

FINTRAC has published a Special Bulletin on the legal profession’s involvement in money laundering, advising firms that lawyers offer a “veneer of legitimacy” to criminal transactions to deter investigation. Common typologies include lawyers managing corporate structures or offshore accounts, misusing trust accounts, and transferring real estate. The report warns of red flags such as:

• Clients represented by lawyers based in other locations. 
• Transactions involving lawyers who are directors at multiple co-located, but otherwise unrelated, companies. 
• Unusual transaction structures, such as using corporate vehicles to purchase residential property. 

It also reminds firms of their obligation to submit an STR if they believe a transaction may be linked to money laundering. 

The UK government’s agency for company registration, Companies House, has released its first strategic intelligence assessment on the criminal misuse of its services. The report acknowledges the major role of UK limited companies in money laundering, citing high-end, trade-based, and cash-based money laundering as the main typologies. It also announces the creation of two new intelligence teams to tackle this, supported by £20m from the Economic Crime Levy until 2026. 

MAS has published Singapore’s National Anti-Money Laundering Strategy, outlining its approach to prevention, detection, and enforcement. Key measures planned as part of the strategy include: 

• A cross-governmental data-sharing platform, the National AML Verification Interface for Government Agencies Threat Evaluation (NAVIGATE), and expanded private sector data-sharing channels. 
• An AML Sensemaking workgroup to oversee technological development. 
• Enhanced beneficial ownership requirements. 
• Amendments to the Mutual Assistance in Criminal Matters Act (MACMA) to aid international enforcement. 

Firms should consult the full report for details, as well as the National Risk Assessments on which the strategy is based. 

Until next week,

Andrew Davies, Global Head of Regulatory Affairs.