Anti-Money Laundering Procedures

Anti-Money Laundering Procedures

Last updated: 18 June 2026

1. Our Approach

Pembridge Solicitors Limited is committed to preventing money laundering, terrorist financing, fraud and other financial crime. As a regulated law firm, we are required to carry out checks on clients, matters and certain transactions before and during legal work.

These checks help us confirm who we are acting for, understand the purpose of the work, assess risk and comply with our legal and regulatory obligations.

2. About Pembridge Solicitors

Pembridge Solicitors Limited is a law firm based in Cheltenham. We are authorised and regulated by the Solicitors Regulation Authority under SRA number 625038.

3. Why We Carry Out Checks

Law firms are required to take steps to prevent their services from being used for money laundering, terrorist financing or other unlawful activity. This means we may need to ask clients for information and documents before we can open a file, continue acting, receive funds or complete certain work.

These checks are a normal part of using a regulated law firm. They do not mean that we suspect a client of wrongdoing.

4. Identity Checks

We may ask you to provide documents or information to confirm your identity and address. This may include:

• passport, driving licence or another accepted form of photo identification;
• proof of address, such as a utility bill, council tax bill, bank statement or other accepted document;
• date of birth and contact details;
• electronic identity verification where appropriate;
• additional documents if the matter carries a higher risk.

We may need to update identity checks during a matter if required by law, regulation or our risk assessment.

5. Source Of Funds And Source Of Wealth

In some matters, we may need to understand where money has come from and how funds or assets have been built up. This is known as source of funds and source of wealth checking.

Depending on the matter, we may ask for documents such as:

• bank statements;
• payslips or employment income evidence;
• business accounts or tax documents;
• sale contracts or completion statements;
• gift letters and evidence of the donor’s funds;
• loan agreements or mortgage documents;
• probate, inheritance or trust documents;
• evidence explaining transfers between accounts.

We may need to ask follow-up questions if documents do not clearly explain the source of money or if the information provided does not match the transaction or instructions.

6. Business Clients And Organisations

If we are instructed by a company, partnership, charity, trust or other organisation, we may need to identify and verify the organisation, its ownership and the people who control it.

This may include checks on directors, shareholders, partners, trustees, beneficial owners, authorised signatories and people giving instructions on behalf of the organisation.

7. Politically Exposed Persons And Sanctions Checks

We may carry out checks to identify if a client, beneficial owner or connected person is subject to sanctions, is a politically exposed person, or is connected to a higher-risk jurisdiction or activity.

If additional checks are required, we may ask for more information before we can proceed.

8. Ongoing Monitoring

Anti-money laundering checks are not always limited to the start of a matter. We may review and update information during the matter, especially if instructions change, funds are introduced, new parties become involved or new risks are identified.

9. Third-Party Payments

We may need to ask questions if funds are being paid by someone other than the client, or if funds are being sent to someone other than the client. We may ask for identification, source of funds evidence and a clear explanation of the reason for the third-party payment.

We may refuse to accept or make a third-party payment if we cannot complete the required checks or if the payment creates a risk we cannot properly manage.

10. If Checks Cannot Be Completed

If we cannot complete the required anti-money laundering checks, we may not be able to act for you, continue acting, receive money, transfer money or complete the work requested.

In some circumstances, we may also be restricted from explaining the reason for a delay or decision if the law prevents us from doing so.

11. Confidentiality And Reporting Duties

We owe professional duties of confidentiality to clients. However, those duties are subject to legal and regulatory obligations.

If we are required by law to make a report to the relevant authorities, we may have to do so without telling you. This can happen where there is a legal obligation connected to money laundering, terrorist financing, sanctions or other financial crime concerns.

12. How We Use AML Information

Information provided for anti-money laundering checks will be used to meet our legal, regulatory, professional and compliance obligations. This may include identity verification, risk assessment, source of funds checks, sanctions screening, file reviews, audits and regulatory reporting where required.

We may use trusted third-party providers to assist with identity verification, electronic checks, sanctions screening and compliance checks.

13. Keeping Records

We are required to keep records of certain anti-money laundering checks. These records may include identity documents, verification results, risk assessments, source of funds evidence, correspondence and file notes.

Records will be retained in line with our legal, regulatory and professional obligations, as explained in our Privacy Policy.

14. Client Responsibilities

Clients are expected to provide accurate, complete and up-to-date information when requested. Delays in providing documents or answers may delay the start or progress of a matter.

If your circumstances change during a matter, or if there is a change in the source of funds, ownership, control, transaction structure or people involved, you should tell us as soon as possible.

15. Privacy And Data Protection

Personal information provided for anti-money laundering checks will be handled in accordance with our Privacy Policy and applicable data protection law.

We do not sell personal information. We only use and share information where there is a proper legal, regulatory, professional or business reason to do so.

16. Questions About AML Checks

If you have questions about our anti-money laundering checks, or if you need help understanding what documents may be required, please contact us.

17. Updates To This Page

We may update this page from time to time to reflect changes in law, regulation, professional guidance or the way the firm carries out anti-money laundering checks.