As a solicitor in practice, it’s important to remember your reporting obligations relating to money laundering and terrorist financing, and the consequences of failing to comply.

In particular, you should take care with certain client behaviours in conveyancing transactions that should cause you to consider whether a suspicious transaction report (STR) may be warranted.

Reporting obligations

Solicitors have an obligation to submit a suspicious transaction report (STR) to FIU Ireland and to the Revenue Commissioners if you know, suspect, or have reasonable grounds to suspect that another person has been or is engaged in an offence of money laundering or terrorist financing.

Depending on the circumstances, failure to comply with this reporting obligation may be categorised as a criminal offence and could result in a fine or imprisonment (or both). 

From a regulatory perspective, a breach of this nature could result in a referral to the Legal Practitioners Disciplinary Tribunal on misconduct grounds potentially leading to a solicitor being struck off. With such grave implications, you are advised to take this obligation seriously. 

Where would an STR be necessary?

There are certain client behaviours which should trigger consideration of a STR. Sometimes, a client may attempt to conceal a transaction or the source of funds, and/or property ownership, from relevant statutory authorities, so remain alert to this possibility.

When it comes to stamp duty, the following behaviours should also be treated with scepticism:

• a failure or refusal on the part of the client to put the solicitor in funds for stamp duty in advance of completion, noting that a solicitor must be in funds in any event in standard residential mortgage lending cases,
• a client seeking the return of stamp duty funds paid by the client to the solicitor where such stamp duty has not been paid to the Revenue Commissioners,
• an instruction not to file a stamp duty return, despite the solicitor’s advice that such a return should be filed, or a refusal to provide information relevant to or funds necessary for such a filing, or
• an instruction to complete and file a return in a particular manner that is not in accordance with the solicitor’s advice or typical practice.

In terms of registration of title, the following client behaviours should warrant closer consideration:

• Failure or refusal by the client to put you in funds for registration fees in advance of completion (you must be in funds in standard residential mortgage lending cases).
• An instruction not to register the title to the property, or to delay or abandon an application for registration.
• An absence of assistance from the client to progress a registration application.

For more information, see the Practice Note: Suspicious transaction reporting in conveyancing. 

Best practice

Consistent good practice can help solicitors and firms to spot issues and remain compliant.

• Firms are strongly encouraged to ensure they are registered with the goAML portal so that relevant personnel can access it promptly when required.
• A STR arising out of a conveyancing case should contain details of the property concerned, including folio numbers and Eircodes where available, to enable relevant authorities to investigate the matter.
• You must ensure that actions taken in response to a suspicion do not constitute tipping off or otherwise prejudice an investigation.
• Firms should have clear internal escalation procedures, including prompt referral to the person responsible for anti-money laundering (AML) reporting within the practice, where applicable.

This article has been adapted from a March 2026 practice note issued jointly by the Law Society’s Regulation of Practice and Conveyancing Committees.