Build the firm's client-acceptance and cash-reporting procedure
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Turn the lawyer's instructions into a procedure covering the Rule 1.16 inquiry and the steps for a Form 8300. Do not write a suspicious-activity program as if the firm were a casino or a bank.
- What the lawyer must review
- Model Rule 1.16(a) requires the lawyer to inquire into and assess the facts and circumstances of each representation, and to decline or withdraw where the client seeks to use the lawyer's services to commit or further a crime or fraud. A required Form 8300 is filed within 15 days, electronically with FinCEN or on paper with the IRS. Check the admitting state's version of Rule 1.16. Do not describe this procedure as an AUSTRAC AML/CTF program.
- Written for / version
- United States versionUS
Who does what
| Role | What they do |
|---|---|
| Assistance | Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Check the current court or regulator requirements, prescribed form and attachments for the intended document and filing.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.