The SRA conducted an audit of the law firm in relation to compliance with the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), which came into force in June 2017. Law firms performing specific types of work are required to comply with the MLRs 2017 by carrying out a risk assessment to identify and assess the business’s risks of money laundering and terrorist financing (known as a AML firm-wide risk assessment).
The SRA requested all relevant law 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 declaration until March 2021, which constituted a breach of the applicable regulations.
As a result of this breach, the SRA directed the law firm to pay a penalty of £800.