The ECHR held unanimously on 6 December 2012, that the obligation on lawyers to report suspicions in the context of the fight against money laundering does not interfere disproportionately with professional privilege.

In this brave new world of OFR, we are faced with, amongst other things, as Donald Rumsfeld said, “known unknowns. That is to say, there are things that we know we don’t know.” At the top of the list for many firms is what is meant by Outcome (1.1) “you must treat your clients fairly”.