As part of the UCIF programme, a training session for notaries and lawyers was held on 3 December, focused on compliance with regulatory requirements for the prevention of money laundering and terrorist financing.
The Strengthening Ukraine’s Capacity to Counter Illicit Finance (UCIF) aims to lay the foundations for a long-term, systemic reform of Ukraine’s financial ecosystem. The project brings together government institutions, regulators, law enforcement agencies, financial institutions, and international partners to reduce the scale of the shadow economy, increase transparency in the financial sector, and combat money laundering. It is implemented by DAI Global with the support of the UK Foreign, Commonwealth & Development Office (FCDO).
This training was organised by the Center for Financial Integrity in partnership with the Centre for Finance and Security (CFS) at RUSI. The event speaker was Olivia Ellison — compliance and sanctions expert, Associate Fellow at RUSI, Advisory Board Member at the Center for Financial Integrity, and former Partner at KPMG.
Every financial transaction carries a risk of money laundering. Notaries and lawyers are considered high-risk due to the nature of their services, which often involve handling assets, real estate, and complex legal structures.
Criminals may exploit their services to conceal the illicit origin of funds, execute fictitious contracts or transfers, legitimise proceeds from criminal activity, and create complex financial schemes that are difficult to trace.
Professional secrecy can complicate oversight but does not exempt notaries and lawyers from monitoring suspicious transactions. Confidentiality does not extend to illegal activities, as stated in Article 10 of the Law of Ukraine No. 361-IX “On Prevention and Counteraction to the Legalisation (Laundering) of Proceeds from Crime, Financing of Terrorism, and Financing the Proliferation of Weapons of Mass Destruction”.
A risk-based approach is an effective method for preventing money laundering and terrorist financing, as it allows attention to be focused on transactions, clients, and processes that pose genuinely elevated risks, rather than applying the same standards to all cases. This approach is embedded in the FATF international recommendations and has been incorporated into Ukrainian legislation regulating the activities of notaries, lawyers, and other high-risk professions.
It is important not merely to comply formally with requirements but to understand the real risks faced by your firm and to develop processes that allow effective control.
A risk-based approach is an effective method for preventing money laundering and terrorist financing, as it allows attention to be focused on transactions, clients, and processes that pose genuinely elevated risks, rather than applying the same standards to all cases. This approach is embedded in the FATF international recommendations and has been incorporated into Ukrainian legislation regulating the activities of notaries, lawyers, and other high-risk professions.
It is important not merely to comply formally with requirements but to understand the real risks faced by your firm and to develop processes that allow effective control.
To achieve this, firms should:
1. Identify risks in each transaction, taking into account the specifics of the client, country, and type of financial activity;
2. Document the risk assessment process and ensure it is applied in practice;
3. Keep records of all measures and decisions to enable verification and continuous improvement.
The guiding principle is simplicity and practicality: it is better to have a straightforward process that is consistently followed than a complex procedure designed by a consultant that is never applied in practice.
Enhanced oversight of high-risk sectors, such as notaries and lawyers, is critical for preventing money laundering and terrorist financing. Workshops like this support professionals in implementing simple, practical approaches that can be applied daily to detect illegal financial flows and stop them in a timely manner.