The AML Clinic Podcast

 Michelle Clement is joined by Suzie Ogilvie to discuss how firms can recognise and manage sanctions risk in practice, apply the "reasonable cause to suspect" threshold, and make defensible decisions that stand up to regulatory scrutiny. 

Sovereign wealth funds and state-linked structures are often perceived as low risk because they carry an assumption of legitimacy. But how should firms assess these relationships in practice? In this episode, Michelle Clement is joined by Colin Solomon to explore the lessons arising from the Jersey v LGL Trustees Ltd re Angola case, and what it reveals about risk classification, onboarding assumpt...

This episode explores the critical differences between having risk assessments and actively using them in law firms. Hosted by Michelle Clement, with AML consultant Kayleigh Smale, it emphasises how effective risk assessments can shape decision-making, influence behaviour, and ensure compliance. This conversation is about what risk assessments are meant to evidence and why that’s harder than it lo...

 In this episode of The AML Clinic Podcast , Michelle Clement is joined by Arik Oslerne to explore one of the biggest shifts currently shaping AML and client onboarding: the rise of AI.  The episode explores:  where AI is currently adding practical value in AML and onboarding   how automation is changing legal workflows and decision-making   the risks of over-reliance, false confidence, and loss o...

In this episode of the AML Clinic podcast, host Michelle Clement, a former SRA AML Regulatory Manager, explores the often-overlooked aspect of recruitment in the context of AML compliance. Joined by Lauren Eager, a principal consultant at QED Legal, they discuss how hiring decisions reflect a firm's operational priorities, investment in compliance, and response to regulatory pressures. The co...

In this concluding episode of a three-part series, The AML Clinic Podcast brings together the core themes explored across the trilogy: how the SRA assesses seriousness, what it looks for in AML file reviews, and how internal decision-making shapes regulatory outcomes. Michelle Clement (former SRA AML Regulatory Manager) focuses on where outcomes are truly determined in practice, at the point where...

 In this episode, former SRA AML Regulatory Manager Michelle Clement explains what the SRA actually looks for when reviewing your files, why technically complete files often fall short, and how to ensure your approach stands up to scrutiny. 

 In this episode of the AML Clinic Podcast, Michelle Clement explores how the SRA determines whether a breach is “serious” in practice.  Understanding how to evaluate the seriousness of breaches is essential for law firms. Many firms grasp the rules, but fewer truly understand how the SRA assesses seriousness. Knowing this can help you make defensible decisions and avoid unnecessary panic when iss...

In this episode, the tables are turned as I’m interviewed by Pearl Moses, the Former Head of Risk and Compliance at the Law Society who came prepared with questions gathered from AML professionals across the legal sector. We discuss the biggest AML mistakes many law firms make , what ''does it make sense” means in practice, and how firms can challenge factual inaccuracies or misinterpret...

In this episode of the AML Clinic podcast, host Michelle Clement engages with Colin Solomon, a senior specialist in offshore financial services, to explore the complexities surrounding offshore jurisdictions and their associated AML risks.  The conversation delves into why offshore entities are deemed inherently risky, emphasising the need for a nuanced understanding of risk that transcends simpli...

What would it mean for law firms if AML supervision shifted from the SRA to the FCA? And what can the legal sector learn from financial services right now? In this episode of The AML Clinic Podcast , Michelle is joined by Chantelle Obatolu, Financial Crime Specialist and Assistant Vice President in AML at Sumitomo Mitsui Banking Corporation. With extensive experience across global banks and consul...

In this episode of the AML Clinic podcast, host Michelle Clement and guest Ray Blake delve into the complexities of onboarding a corporate client within the framework of anti-money laundering (AML) compliance. They explore the critical distinctions between identifying and verifying corporate clients, the role of Special Purpose Vehicles (SPVs), and the importance of understanding ownership structu...

In this episode of The AML Clinic Podcast , Michelle Clement speaks with Christian Hunt , author of Human Risk , about why compliance failures in law firms are rarely caused by bad individuals and are more often the result of poorly designed systems. They explore how behavioural science can improve AML and compliance outcomes, why traditional approaches like policies and training often fail, and h...

In this episode of the AML Clinic podcast, host Michelle Clement interviews Luke Haddon, the money laundering reporting officer at Keystone Law. They discuss Luke's career path, the proposed changes to the UK's money laundering regulations, and the implications of these changes for law firms. Luke expresses concerns about the introduction of pooled client accounts and emphasizes the impo...

In this episode of the AML Clinic Podcast, Michelle Clement and Eloise Butterworth discuss the evolving legislative landscape for law firms, focusing on AML compliance, resourcing hurdles, and the role of technology. Eloise shares her journey from family law to risk and compliance, emphasising the importance of clarity, training, and culture in managing AML obligations. They also explore the finan...

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation al...

In this episode of the AML Clinic podcast, host Michelle Clement and guest Alison Matthews delve into a case study involving a conveyancing matter and the application of the Proceeds of Crime Act (POCA). They discuss the importance of verifying the source of funds, the challenges of anti-money laundering compliance, and the role of the Money Laundering Reporting Officer (MLRO). The conversation al...

In this episode of the AML Clinic, Michelle Clement and Graham Mackenzie discuss the critical issue of money laundering in law firms. They explore the vulnerabilities within legal services, particularly in conveyancing, the role of trust and company service providers (TCSPs), and the implications of tax advice. The conversation also addresses the risks associated with probate and busts the myth th...

In this episode of the AML Clinic podcast, host Michelle Clement interviews Christopher Christou, a solicitor who shares his experiences with SRA AML inspections. The conversation covers the emotional journey of receiving an inspection notice, the preparation involved, and the importance of compliance in law firms. Christopher discusses the challenges of running a small firm, the role of technolog...

In this episode of The ANL Clinic, we dive into one of the most critical and often misunderstood  areas of financial crime prevention: the difference between source of funds and source of wealth. We explore a real Solicitor Disciplinary Tribunal case involving a politically exposed person, a £1.1 million transaction and a £1.9million transaction, and serious gaps in due diligence. Key takeaways: W...