Review of AML Policies 2025

As part of the practising certificate renewal applications, notaries are required to submit a copy of their Anti-Money Laundering Policies & Procedures (including Firm Wide Risk Assessments).

The Faculty Office reviewed 70 randomly selected AML policies and/or Firmwide Risk Assessments (FWRA) for notaries across a range of risk categories. The Risk breakdown is as follows:

• 5 High Risk notaries
• 13 Moderate risk notaries
• 52 Low Risk notaries

To verify whether risk levels were appropriately classified, we also selected a small number of notaries from within the sample who reported that they do not fall within the scope of the Money Laundering Regulations 2017 (MLRs).

This additional selection was prompted by the observation that, in the FWRA templates used in the majority of cases, notaries often included qualifying terms such as “mostly” or “mainly” when referring to the application of relevant exclusions. These qualifiers raised questions about the consistency and accuracy of self-assessed regulatory scope.

The full report and results of the review are available to view here.