Addendum to the 2023 edition of the Legal Sector Affinity Group Guidance

This addendum contains legislative updates and shows a change in LSAG’s position and expectations. The areas covered include:

  • Economic Crime Levy considerations for larger firms
  • Discrepancy Reporting Guidance
  • Registers of Overseas Entities update
  • Changes brought in by the Economic Crime Act, including a new POCA de minimis limit of £1,000
  • A definition of Supply Chain Risk, which is particularly relevant in the context of financial sanctions requirements
  • Supervisory expectations in respect of evidencing Third-Party Source of Funds involved in a transaction
  • LSAG-proposed amends to the Identification & Verification approach set out in existing LSAG guidance
  • Erratum: Beneficial Ownership thresholds.