Published April 15, 2026 | Version v1
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LAWYERS AS AML/CFT GATEKEEPERS IN UZBEKISTAN: LEGAL CHALLENGES AND FUTURE PROSPECTS

Description

This article examines the potential role of lawyers as gatekeepers within the anti-money laundering and counter-terrorist financing (AML/CFT) framework in Uzbekistan, focusing on the legal challenges and prospects of integrating the legal profession into preventive financial-crime regulation. While international standards, particularly those developed by the Financial Action Task Force (FATF), increasingly require lawyers to perform customer due diligence and reporting functions, such obligations have not been fully implemented in Uzbekistan. The article analyzes the existing national legal framework and identifies key challenges, including tensions with attorney–client privilege, concerns over professional independence, and the absence of clear regulatory mechanisms. By comparing international approaches with the current Uzbek context, the article highlights the risks of both under-regulation and over-regulation of the legal profession. It argues that the introduction of gatekeeping obligations must be carefully balanced with fundamental professional guarantees and proposes a gradual, risk-based and self-regulatory model tailored to national legal realities.

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