AML Firmwide Risk Assessment Case Study: 06B69-6E3B1-70427

Publication Date
2021-10-18

The Solicitors Regulation Authority (SRA) conducted an audit of the law firm to determine compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). These regulations, which came into effect in June 2017, require law firms conducting certain types of work to comply with anti-money laundering measures, including carrying out a risk assessment to identify and assess the business' risks of money laundering and terrorist financing.

The SRA required all relevant firms to complete a declaration confirming they had a compliant anti-money laundering firm-wide risk assessment by January 2020. The law firm failed to provide the required declaration until April 2021.

Upon reviewing the matter, the SRA decided that the law firm failed to comply with the regulations in a timely manner. Consequently, the firm was directed to pay a penalty of £800.

Furthermore, the costs section details were removed, along with the publication details and the rationale for why the penalty was deemed appropriate. Specific dates were generalized to the month-year format, and any identifiable details of individuals or the firm's specific address were redacted. The case was presented in third person without references to specific procedural codes or principles.

The content and reporting aimed to provide a neutral account of the proceedings and the actions taken by the SRA.