- Publication Date
- 2024-03-18
The Solicitors Regulation Authority (SRA) carried out an investigation into a law firm following a desk-based review by its AML Proactive Supervision team. This review identified areas of concern regarding the firm's compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017).
Between June 2017 and February 2023, the firm had Policies, Controls, and Procedures (PCPs) in place that were not compliant with Regulation 19 of the MLRs 2017. The AML policies, controls, and procedures provided as part of the desk-based review did not cover multiple mandatory areas set out in the regulations. On July 2023, the firm provided a copy of its updated PCPs, which were compliant with the MLRs 2017.
Furthermore, between June 2017 and February 2023, the firm failed to conduct an adequate Client and Matter Risk Assessment ( CMRA) process, as required by Regulation 28 of the MLRs 2017. The review showed that clients and matters were not being risk assessed adequately. Later, in July 2023, the firm provided documents showing that a new client and matter risk assessment process was implemented and compliant with Regulation 28 of the MLRs 2017.
The firm admitted that by failing to comply with the MLRs 2017 from June 2017 to November 2019 (when the SRA Handbook 2011 was in force), and from November 2019 to February 2023, it breached several SRA Principles .