AML Firmwide Risk Assessment Case Study: 6C321-1BDA9-1FD69

Publication Date
2023-07-10

The Solicitors Regulation Authority (SRA) conducted an audit and fined a law firm £4,000 for failing to have a documented and compliant AML firm-wide risk assessment, not having compliant policies, controls, and procedures (PCPs), and failing to nominate a money laundering compliance officer. These actions were contrary to the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). Additionally, the firm did not obtain an accountant's report for the 2020/2021 year.

It was found that from June 2017 until October 2021, the law firm failed to establish a documented and compliant AML firm-wide risk assessment and did not adequately consider the SRA’s warning notice on firm-wide risk assessments issued in May 2019 and updated in November 2019.

From June 2017 until July 2022, the law firm did not have up-to-date anti-money laundering (AML) AML policies, controls, and procedures to mitigate and manage the risks of money laundering and terrorist financing.

Between March 2019 and April 2022, the law firm failed to nominate a money laundering compliance officer as required by the Money Laundering Regulations 2017. Furthermore, the law firm did not obtain an accountant’s report for the year 2020/2021, thereby breaching the SRA Accounts Rules.

The SRA directed the law firm to pay a financial penalty of £4,000 and ordered it to pay costs of £1,350 due to the seriousness of its conduct, which breached its regulatory obligations for over four years. The law firm’s actions had the potential to cause harm to the public interest and to public confidence in the legal profession.