Summary Introduction
Money laundering occurs when money generated by criminal activities (for example, drug smuggling or terrorism) is paid to a respectable body such as a firm of patent attorneys, and then subsequently withdrawn, its criminal connections nicely washed away, for re-use. Since we handle money for our clients, albeit usually relatively small amounts and for short periods, we are potentially vulnerable to this type of practice.
You are obliged by law, under the Proceeds of Crime Act 2002, to look out for ‘suspicious’ circumstances which might indicate that a client, or indeed any other contact, is involved in money laundering.
An example might be overpayment of a bill, or payment in advance, followed by a request for repayment, although not every instance of this will indicate that money laundering is going on. Another example might be an unusual billing arrangement, typically involving payments being made to or from an entity other than the instructing client.
Suspicious circumstances such as these have to be notified immediately to the Serious Organised Crime Agency (SOCA), in a specified format. Failure to notify is a criminal offence. With luck you will never find yourself in such a situation, but be on your guard and if you do spot suspicious activity, talk to your supervisor at once. You must not warn the client of your suspicion (this too is a crime), but nor must you do any further work for him without SOCA’s authorisation: an extremely tricky position to be in, and one for which there is as yet little useful guidance.
Note: this type of legal obligation overrides your duty of confidentiality to the client.
If, with regard to the above points, you have any suspicions at all about any client or potential client, please inform the Managing Director immediately, before accepting any instructions.
For further detailed information, see:
3.1.2 Collecting Information for a New Client Record
Back to 3. General Company Policies
Last Updated on 29 October 2025 by Keith