AML: New Intelligence and a Note of Caution

23 April, 2025

The CLC has received some intelligence that fraud and/or money laundering operations that were operating in Liverpool and Manchester prior to 2018 may be active again.

A hallmark of these operations is the use of “vendor gifted deposits”. Such deposits can take a few forms, but they may be comprised of “loans” on completion from the vendor which are intended to be immediately repaid.

Another kind we have been alerted to are “vender invoices” which are to be paid on completion. Such types of vendor deposit could be aimed at committing mortgage fraud and/or tax fraud as it pertains to stamp duty land tax (SDLT).

If any CLC practice comes across such types of vendor deposit you must ensure that the transaction is scrutinised carefully and that the source of funds is examined just as carefully, with appropriate records retained on file.

If a practice holds any suspicions about any such activity, you should consider making an intelligence Suspicious Activity Report (SAR) to the National Crime Agency (NCA) and reviewing whether it is appropriate to act for that client.

The CLC would also welcome any intelligence on similar schemes; practices can email our dedicated AML inbox at: aml@clc-uk.org.