AML Legal Counsel

An AML legal counsel specializes in interpreting and applying the regulatory framework for anti-money laundering and counter-terrorist financing (AML/CFT). The counsel assists companies in ensuring compliance by drafting policy documents, conducting risk assessments, providing staff training, and supporting communication with supervisory authorities.

An AML legal counsel identifies and manages risks associated with the organization potentially being used for money laundering or terrorist financing. This includes risks such as:

• Deficiencies in know-your-customer (KYC) processes and customer due diligence.
• Inadequate internal procedures and controls.
• Incorrect or missing reporting to authorities.
• Challenges in interpreting and implementing new regulations.

The anti-money laundering regulations apply not only to banks and financial institutions but also to accounting firms, auditors, law firms, real estate agents, currency exchange services, and others. Fintech and crypto companies may also fall under the scope. Morling Consulting helps you assess whether and how the regulations apply to your business.

Policy documents such as the general risk assessment and internal AML instructions form the foundation of the AML compliance work. The regulatory framework requires that the documents are tailored to the specific risks of your business and updated regularly. Outdated or inadequate documents reduce your organization’s ability to prevent money laundering and terrorist financing, thereby increasing the risk of non-compliance.

It is especially important to review and update AML documentation in situations such as:

• Changes in legislation or regulatory practices.
• Changes in the organization’s business model or customer base.
• Findings from internal or external audits.
• Identified deficiencies in regulatory inspections or reviews.

The general risk assessment is an analysis of the risks that the business may be exploited for money laundering or terrorist financing. It forms the basis for how the organization designs its internal AML/CFT procedures. An AML legal counsel can assist in developing or updating this assessment in accordance with current regulatory requirements.

Engaging an external AML legal counsel is particularly valuable in situations involving supervisory authority dialogue, internal audits, GAP analyses, the implementation of new regulations, or when internal resources are scarce. Morling Consulting also offers interim solutions, where an AML specialist provides support on a full-time or part-time basis for a set period.

We provide customized AML/CFT training tailored to different roles within your organization—from senior management to customer-facing staff. The training covers legislation, practical case studies, internal procedures, and typologies. Courses are led by experienced AML legal counsels and adapted to your industry and risk exposure.

We offer:

• legal advisory services, document review,
• risk assessments, training, support in regulatory communications, and
• interim assignments.

We work with both Swedish and international clients and have experience implementing AML programs in everything from startups to large corporate groups.

An AML GAP analysis maps the difference between the organization’s current AML compliance status and the requirements set by laws and regulations. The analysis may include:

• Review of policy documents and procedures.
• Assessment of internal controls and risk management.
• Identification of improvement areas.
• Recommendations for corrective actions and priorities.

Common mistakes include underestimating the need for ongoing training, relying on generic rather than business-specific risk assessments, and drafting policy documents without fully implementing them in practice. An AML legal counsel helps avoid these pitfalls.

The anti-money laundering regulations require that training be conducted regularly and tailored to the employees’ roles and responsibilities. The recommendation is at least annually, or more frequently in case of significant regulatory changes or shifts in the organization’s risk exposure.