Our AML/CTF/KYC Processes

Our AML/CTF/KYC checking system is transparent, thorough and reflects the highest industry standards.

We have a 20-strong team of professionals in the UK and France, supported by a network of AML/CTF/KYC and wider Risk specialist lawyers across the jurisdictions in which we practise.

Our policies, controls and procedures are supported by state-of-the art technology. We use the Intapp screen-based client onboarding system, which is smooth, rigorous and compliant, and LexisNexis® IDU®, a digital platform which allows us to check identity information against authoritative sources to reduce the risk of identity fraud. We educate our partners and employees about their individual AML/CTF/KYC and anti-bribery and corruption obligations with regular, up-to-date, industry standard training modules.

To reflect the proliferating AML/CTF/KYC risk, we insist that our partners take personal responsibility for the clients they onboard and that they are held to account in this respect by our Onboarding Risk Committee of specialist partners.

Russian Onboarding

In response to the conflict in Ukraine, in March 2022 we established a Russian Client Onboarding Committee (RoCC) to evaluate prospective new instructions for Russian related work.

The Committee requires any proposal to be compliant with all sanctions legislation and will not accept work which assists Russian military action in Ukraine in any way, or is conducted for Russian Oligarchs, Russian state-backed entities or any individuals who are close to the current Russian regime.

The RoCC enables the firm to apply forensic scrutiny when assessing incoming instructions and adopt a consistent approach to Russian-
related work.

To reinforce and amplify those standards, in 2023 the firm introduced a Behavioural Code which positions integrity and ethical behaviour at the heart of our
ERM programme.

The Risk Group delivers regular training and guidance to partners and staff around our SRA and firmwide behaviour expectations.

We spend regular fortnight periods working alongside each Business Unit to raise the profile of the firm's ERM and ESG obligations, reinforce the role of good governance and good behaviour and spread awareness of our online Risk Learning Management System and dedicated intranet pages on risk, compliance and governance.

Our expectations are clearly set out in a suite of policies readily available to all staff, which include those addressing Acceptable Use, Social Media and the SRA's Workplace Environment Guidance.

Data Governance

Fieldfisher is committed to protecting the privacy and security of the client and employee data it holds.

The confidentiality and security of client information is mandated by both the SRA Codes of Conduct, as well as wider regulatory obligations including the General Data Protection Regulation (GDPR). We have a dedicated Data Protection Officer to monitor compliance with this regulation.

The Firm has made significant investment into upgrading its information security systems this year. The Risk Group has also delivered an increased number of training sessions on data protection in 2023.

Integrity and Ethical Behaviour

We have a regulatory imperative as a law firm to ensure standards of integrity and ethical behaviour which align with the SRA's Standards and Regulations.