CQS Practice Standard · Section 5.12

CQS (CPMS) Anti-Money Laundering Policy

The recent update to the CQS Core Practice Management Standards (CPMS) requires CQS firms to have a policy in place in relation to anti-money laundering (s5.12).

CQS Policy documents can be time-consuming and difficult to prepare without a Policy Template as a starting point.

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Aligned to CQS CPMS Section 5.12 Last updated 2026-08-20 Maintained by Lexsure

What the policy covers

60 sections in the current version.

Change Control
Document Control
Associated Policies
1 Overview
2 Money Laundering Regulations 2017 (as amended)
3 Training
3 1 AML Training
4 Roles
5 Client Due Diligence (CDD)
6 Client identification
6 1 Identification and verification
6 2 Documents
6 3 Clients who are not physically present
6 4 Reliance on others
6 5 Evidence required
6 6 Lack of evidence of ID
6 7 Digital identity verification and Trust Framework compliance
7 Beneficial owners
7 1 Duty to identify beneficial ownership
7 2 Checking beneficial owners
8 Risk assessment
8 1 What is risk assessment?
8 2 Enhanced due diligence: high risk matters and clients
8 3 Politically Exposed Persons (PEPs)
8 4 Simplified due diligence – low risk clients and matters
8 5 Supply chain risk
9 Ongoing monitoring
9 1 What is ongoing monitoring?
9 2 Sources of funds
9 3 Sources of Wealth (SoW)
9 4 2025 LSAG Guidance + Checklists
10 Reporting suspicious transactions
10 1 Why report?
10 2 Privilege
10 3 Asking the client to clarify
10 4 Tipping off / prejudicing an investigation
10 5 How to report
10 6 Authorised and protected disclosures
10 7 Responding to AML enquiries from the authorities
10 8 5MLD requirements – reporting on a company's beneficial ownership
10 9 Submitting better quality Suspicious Activity Reports (SARs)
11 Detecting money laundering
11 1 Suspicion
11 2 Grounds for suspicion: general
11 3 Grounds for suspicion: property
11 4 Chinese underground banking and funds from China
11 5 Commercial Property and High Street Retail Fronts
11 5.1 Risk Overview
11 5.2 Enhanced Due Diligence
11 5.3 Compliance Controls
11 5.4 Red Flags and Escalation
11 6 High-risk third countries
11 7 Registered charities
12 Cryptocurrencies and other new technologies
13 Cash receipts
14 Financial sanctions
14 1 Sanctions basics
14 2 UK Sanctions List
15 New products, business practices or technology
16 Monitoring & review
17 Data collection accuracy
18 Regulatory transition – supervisory transition & data readiness
19 Acknowledgement provision

The Anti-Money Laundering Policy Template includes reference to:

Money Laundering Regulations
Client Due Diligence (CDD)
Enhanced due diligence: High risk matters and clients
Reporting suspicious transactions

...as well as other formalities and general obligations as required under 5.12 of the CPMS.

Latest updates

Own an earlier version? Buy only the paragraphs that have changed. Each paragraph arrives by email as a PDF as soon as you pay.

20 August 2026

Latest Policy Paragraphs, August 2026 3 paragraphs

Enhanced due diligence: high risk matters and clients - updated

In light of the latest SRA sectoral risk assessment this section now extends to cover proliferation financing risk, with a cross-reference to LSAG guidance sections 5.3.1, 5.4.1 and 18.10 as the SRA directs.

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Updated 5MLD requirements – reporting on a company’s beneficial ownership

A new paragraph before the 30-day reporting window directing fee earners to verify that a company client is currently and properly registered at Companies House, with a note about the risk of criminals using documentation from dissolved or struck-off companies.

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Russian sanctions circumvention

Covers the OFSI/OTSI guidance on third-country routing, dual-use goods, and layered ownership structures, with a clear escalation obligation to the MLRO.

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13 July 2026

Latest Policy Paragraphs, July 2026 1 paragraph

Enhanced Due Diligence: High-Risk Matters and Clients (update)

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 have overhauled EDD triggers, introducing mandatory Sterling thresholds and specific digital asset controls while replacing the old High-Risk Third Country framework. This draft updates reflects these new statutory triggers, updated compliance rules, and risk classifications to ensure full regulatory alignment

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15 April 2026

Latest Policy Paragraphs, April 2026 1 paragraph

Digital Identity Verification and Trust Framework Compliance

To satisfy statutory DIATF certification and HM Treasury guidance, firms must integrate digital anti-impersonation results into their Policy. Failure to verify certified status risks regulatory non-compliance.

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18 February 2026

Latest Policy Paragraphs, February 2026 1 paragraph

Enhanced Verification for Digital Asset Sources

Implement mandatory independent verification for cryptocurrency funds to satisfy the latest digital asset regulations. Access updated wording to ensure your internal procedures remain compliant with current practice standards and enhanced due diligence requirements.

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14 January 2026

Latest Policy Paragraphs, January 2026 1 paragraph

Regulatory Transition - Supervisory Transition & Data Readiness

Paragraph acknowledges that that you are aware of the oversight change and are preparing your data/files for FCA-style scrutiny (which is more data-led than the SRA)

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20 October 2025

Latest Policy Paragraphs, October 2025 1 paragraph

High-risk Third Countries (update)

Explains that the firm requires Enhanced Due Diligence (EDD) for any matter involving individuals or entities from FATF-designated high-risk third countries. Lawyers must monitor updates to FATF lists—released after plenary sessions each February, June, and October—and ensure compliance with the latest classifications.

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Related CQS policies

Exclusions to note

Sample template bundles do not include a template to show the structure of the residential conveyancing department at a firm. The data protection policy template covers the requirements of CQS, however it is the responsibility of the firm to ensure it is compliant with the requirements of the General Data Protection Regulation.