AML Policy Case Study: 4B4D4-62362-55C42

Publication Date
2024-03-04

Following an audit by the SRA, a forensic investigation was conducted into a law firm due to concerns regarding compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) and the Solicitors Accounts Rules 2011.

The investigation identified that between November 2018 and March 2020, the relevant lawyer materially caused, allowed, and contributed to the firm failing to meet customer due diligence obligations in seven conveyancing matters, leading HM Land Registry to initially refuse registration due to concerns about client identification and verification. Additionally, in October 2018, two payments totaling £34,000 were made from the firm's client account that did not relate to underlying legal transactions.

The SRA's findings led to the relevant lawyer admitting to breaching several regulations governing legal practice, including failing to properly supervise client transactions and misusing the firm's client account as a banking facility. These admissions highlighted significant lapses in maintaining compliance with critical anti-money laundering regulations and internal firm policies designed to prevent such infractions.

The calculated financial penalty for these breaches was determined to be £2,376.