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Regardless of whether you think AML regulations go too far, not far enough, or somewhere in the middle, what is indefensible is how opaque the rules are, and enforcement seems to vary drastically from regulator to regulator, firm to firm, or even day to day.

Jeffrey Shaw is of course correct. If money laundering is to be prevented, it should be tackled at the earliest possible stage, i.e when the funds are deposited. Here is an extract from a letter I wrote to my MP recently on the topic of AML as part of PLA's current campaign:-

"...if an aspiring money launderer has already managed to deposit their illicit funds into a UK account of a respectable bank or building society, the money laundering is for all intents and purposes completed at that point, prior to the conveyancer’s involvement. Accordingly, conveyancers are being forced to go to great lengths to attempt to mitigate a risk that they have little ability to prevent. That is not to say that money laundering is not deleterious to society, of course it is. I am simply suggesting that conveyancers have no opportunity to prevent it in practice and therefore the current AML approach cannot possibly have any meaningful positive impact."