How should a law firm structure an AML and Conflicts team?
Explore the best ways to structure your Risk & Compliance team, from centralised hubs to specialised AML and Conflicts desks.
The Short Answer
The most effective structure for a modern law firm is a centralised Business Acceptance Unit (BAU) that reports into the General Counsel or MLRO. This team typically consists of a Head of Business Acceptance, followed by a layer of Senior Analysts or Team Leaders, and a base of Analysts who manage the daily volume of AML checks and conflict searches.
Centralised vs. Decentralised
In the old days, every partner did their own checks. Today, that is a recipe for an SRA investigation. A centralised team ensures consistency. Most UK firms now opt for a 'Hub' model where all new business requests flow into a single queue. This allows for better data oversight and prevents things from slipping through the cracks.
Functional Splits
As a firm grows, the structure usually evolves into three distinct arms:
- Conflicts: High-speed, high-stakes checking for legal and commercial conflicts.
- AML/CDD: Detailed investigative work on Source of Wealth and Source of Funds.
- Quality Assurance: A small, senior oversight function that audits files to ensure the 'Risk' appetite is actually being met on the ground.
The Bottom Line
Structure your team based on your volume and risk profile. Centralisation is the gold standard for consistency, but ensure there is a clear escalation path to the MLRO for the 'tricky' stuff.
Want to know more?
Guide to building a business acceptance function
Should AML and Conflicts sit together or separately?
