AML Firmwide Risk Assessment Case Study: 1DD44-FCBF4-196C6

Publication Date
2023-10-23

The Solicitors Regulation Authority (SRA) conducted an investigation into the law firm following a proactive virtual Anti-Money Laundering (AML) inspection. The investigation identified areas of concern regarding the firm's compliance with the Money Laundering, Terrorist Financing Regulations 2017 and regulatory rules.

In May 2020, the firm declared it was in scope of the MLRs 2017 and had a compliant AML firm-wide risk assessment (FWRA) in place. However, further investigation revealed that a compliant FWRA had not been established until November 2021. Even then, the initial FWRA was inadequate, as it did not cover all required elements and included incorrect references to outdated regulations.

During the virtual inspection, a review of selected client files highlighted deficiencies, such as the lack of proper client and matter risk assessments, and a lack of understanding regarding the ownership and control of a company. These findings indicated significant issues in the firm's AML procedures.

From June 2017 to November 2019, the firm failed to maintain adequate trust, effective business practices, governance, financial, and risk management principles. It also did not comply with the legislation applicable to its business. From November 2019 onwards, these failures continued under the updated SRA regulations.

The firm admitted to these failures and has since taken steps to rectify its AML compliance issues, including implementing changes upon the SRA's advice.