VERITAS · CASE FILE · ENABLERS-LEDGEROFFENDER'S PLAYBOOK · 60–90 min · 1–6 playersAN INVESTIGATOR'S GAMETHEENABLER'SLEDGERFour clients. One law firm. Where do you draw the line?№105
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OFFENDER'S PLAYBOOK · 60–90 min · 1–6 players

The Enabler's Ledger

Four clients. One law firm. Where do you draw the line?

Run a boutique law firm forming trusts for four clients. Two are legitimate, two are laundering. Learn which drafting choices cross the line and which SAR triggers they create.

⚑ You play the gatekeeper. Each accepted client updates your firm's SAR exposure and disciplinary risk.
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Learning objectives

  • 01Recognise the FATF gatekeeper red flags for legal professionals
  • 02Understand where trust structures cross from planning to laundering
  • 03Draft a SAR from a lawyer's client file

Standards mapping

FATF Recommendations and CPD credit

Learning objectiveFATF
Recognise the FATF gatekeeper red flags for legal professionalsR.22, R.23
Understand where trust structures cross from planning to launderingR.22, R.25
Draft a SAR from a lawyer's client fileR.23, R.28
  • R.22 DNFBPs: customer due diligence. Four client intakes are scored as gatekeeper CDD decisions.
  • R.23 DNFBPs: other measures. The reporting obligation and its privilege limits are the core dilemma.
  • R.25 Transparency and beneficial ownership of legal arrangements. Trust drafting choices decide whether control is traceable.
  • R.28 Regulation and supervision of DNFBPs. The closing bar-council review models supervisory consequence.

Also covers: FATF Guidance for Legal Professionals (2019) · IBA principles on professional conduct

CPD credit rationale

1.5 structured hours (1.5 verifiable) — streams: Legal practice ethics, AML/CFT compliance.

Hours are claimed against structured learning: facilitated play against a published set of learning objectives, decisions scored on a rubric, and a written debrief retained by the participant. Reportable-conduct calls plus a drafted report satisfy most ethics-stream CPD requirements.

Evidence retained: Intake decision record; Drafted suspicious report; Bar-council review score.

Table setup · 1–6 players

Best with 3–4 (intake committee)

1Solo study

Four intakes: onboard, decline or report each one.

2Head-to-head

Lawyer versus MLRO; a client is only onboarded when both agree.

3–4Case cell

S1–S4 as an intake committee; the client seat may withhold one fact per intake.

5–6Full table

Add S5 and S6 for a conduct review and SAR-quality score after the fourth client.

Seats at the table

  1. S1Managing partnerOwns the firm's risk appetite and the fee pressure.
  2. S2Onboarding lawyerRuns KYC and drafts the structure.
  3. S3MLRO / compliance officerOwns the SAR decision and tipping-off risk.
  4. S4ClientPresents the instruction and pushes back on questions.
  5. S5Bar council reviewerScores the file against professional conduct rules.
  6. S6FIU liaisonJudges whether the SAR would actually be actionable.

Team rules

  • 01One seat, one voice: a decision is only locked when the seat that owns it says so out loud.
  • 02Every locked decision needs a one-sentence justification the seat would defend in a real file.
  • 03Any player may call a 60-second 'case conference' once per round to force a table discussion.
  • 04The facilitator (or the highest-scoring player of the previous round) keeps time and reads the outcome cards.
  • 05Tipping-off rule: the client seat must leave the table while a SAR decision is discussed.

Rotation — The client seat rotates every intake, playing the client teaches the pressure lawyers face.

How to play

  1. 1.Four client intakes. For each, choose whether to onboard, decline or file a SAR.
  2. 2.Correct calls build reputation; wrong calls raise your firm's exposure score.
  3. 3.End of game: bar-council review scores your judgement and drafting.

Intake 1 of 4

Mr Almeida · retired shipping magnate

Wants a family trust for succession planning; €40m portfolio; clean source-of-wealth file spanning 30 years.

File flags

  • age-appropriate wealth
  • source documented

Your call

Session extension · +80 minutes

Take the session to full length.

Three additional facilitated missions with their own debrief checkpoints. Run them straight after the online round to take this title to a 60–120 minute workshop. Every checkpoint is self-marking — tick what you can genuinely defend.

Four harder intakes, including one existing client whose circumstances have changed.

Tasks

  1. 01Onboard, decline or report each.
  2. 02For the existing client, decide whether to exit the relationship and how.
  3. 03Record the reputational and exposure score after each call.

Checkpoint · Mark the intake calls.

Debrief · discuss with your team

  • Q1.Which client was the hardest call and why?
  • Q2.How does your jurisdiction reconcile privilege and reporting?