The AML Clinic Podcast

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 issues arise.

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 misinterpretations during SRA engagement.
We also explore what the SRA looks for when reviewing files, what the FCA's take over means for the legal sector today, and why firms should focus on building defensible AML frameworks that stand up to scrutiny.

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 simplistic categorisations. Solomon argues that while there are bad actors in offshore jurisdictions, the perception of risk is often influenced by regulatory caution and media narratives. He provides practical insights for law firms on how to assess offshore structures and beneficial ownership, advocating for a risk-based approach that prioritizes understanding over assumptions.

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 consulting firms, Chantelle shares practical insight into how the FCA approaches AML supervision in practice.
They discuss:
The FCA’s supervisory style and what reviews look like in reality
How deep the FCA goes into governance, systems, culture, and files
AML reporting expectations and how data drives supervision
Senior accountability under the SMCR 
What effective remediation looks like
What law firms can do now to be “FCA-ready”
Whether or not formal change happens, expectations around accountability, evidence, and risk management are rising. This episode offers clear, practical lessons for MLROs, compliance leaders, and law firm decision-makers navigating an evolving regulatory landscape.
Tune in to stay informed, stay compliant, and stay ahead.

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 structures. The conversation highlights the red flags associated with SPVs, the limitations of relying solely on Companies House for verification, and the regulatory requirements for directors. 
The episode concludes with practical advice for firms navigating due diligence processes, emphasising the need for thorough documentation and understanding of the regulatory landscape.