Prepare your business for the new pooled client account legislation

Time is running out if you want to stay ahead of the legislative changes affecting lawyers who use pooled client accounts, which come into force on January 1st 2026. The new rules introduce additional obligations and are not only about what you must do, but also how you can demonstrate that you are doing it correctly.

Below is a short checklist to help you prepare for the upcoming changes.

1. Review your existing client accounts

A good place to start is by gaining a clear overview of your existing client accounts. This will help you identify where your efforts should be focused. For example, consider the following questions:

• Which pooled client accounts do you currently operate?

   

• What types of clients and transactions pass through them?

   

• Which banks do you work with?

If you have not already documented this type of overview – for example in an Excel spreadsheet – now is a good time to do so. Documentation is essential for AML compliance: better too much than too little.

The new rules also apply to existing accounts, meaning you must obtain any missing client information and prepare to share it with your financial institution.

2. Update your KYC procedure 

When onboarding a new client, you should already be collecting identification information. This information must be shared as soon as funds are received into a pooled client account, unless otherwise agreed in writing with your bank. Following the legislative change, you must be able to link the identification information to the specific account into which the client’s funds are paid.

This means you must:

• Collect information on the beneficial owners of the funds held in the pooled client account (and document this).

   

• Ensure that the information can be shared securely with the bank.

A key recommendation is to keep all documentation in one place, making it easy to demonstrate compliance. A digital, GDPR-compliant solution is by far the most efficient approach – both in daily operations and in ensuring documentation is always ready in the event of an inspection.

3. Speak with your bank

Financial institutions require this information to meet their own AML obligations, and the new section 38b of the Anti-Money Laundering Act provides you with a clear legal basis for sharing the necessary information. Remember that you should only share information required for the bank’s customer due diligence. Your duty of confidentiality still applies to all other information.

It is advisable to engage in dialogue with your bank about:

• How they prefer to receive the information

• Whether ongoing updates are required

• Where responsibility lies if circumstances change

4. Update your internal documentation

It cannot be said often enough: documentation is critical in all aspects of AML compliance. You should therefore ensure that your internal AML policy and risk assessment are updated to reflect the new legislation and the requirements it introduces.

Document everything – from when and how information is collected, to how it is shared with the bank. This is not only good compliance practice, but also helps ensure that everyone in your firm is aligned and clear on how client relationships involving pooled client accounts should be handled.

5. Make it easy for yourself

Legislation can feel complex, and practical implementation can be challenging. Fortunately, a digital solution can significantly simplify the process. A platform such as Creditro can help you with:

• Collection and validation of client information

• Screening of beneficial owners

• Documentation and storage of data in accordance with AML legislation

When everything is gathered in one place, it becomes much easier to meet the requirements – and to prove that you do.

We can support you every step of the way

At Creditro, we work to make compliance understandable, efficient and as simple as possible. Our goal is not to overwhelm you with legal provisions, but to provide you with the overview and tools you need to do things correctly.

We have developed Creditro Comply Light to address the specific need related to the legislative update. With this solution you get simple ID collection and storage in a GDPR compliant and safe way. 

If you would like to explore whether Comply Light is the right solution for you, you are always welcome to get in touch.