AML Firmwide Risk Assessment Case Study: 76B6E-43945-5675F

Publication Date
2023-08-31

The Solicitors Regulation Authority (SRA) conducted an audit resulting in a fine of £5,250 for the law firm for failing to have in place a compliant AML firm-wide risk assessment and Anti-money laundering (AML) policies, controls, and procedures between June 2017 and July 2022. The information provided by the firm in response to the SRA's request for details on their AML documentation was found to be inaccurate.

It was determined that the relevant lawyer, as the sole owner and manager of the law firm, failed to implement a compliant AML firm-wide risk assessment during the specified period and did not give sufficient consideration to the SRA’s warning notice on firm-wide risk assessments issued in May 2019. This non-compliance persisted over a period of five years, indicating a serious breach of regulatory obligations.

Furthermore, between June 2017 and July 2022, the relevant lawyer did not ensure that the firm had appropriate AML policies, controls, and procedures, leading to additional breaches.

The relevant lawyer also provided inaccurate information by declaring in October 2020 that the AML firm-wide risk assessment was compliant with regulatory requirements and later, in October 2021, stating that the firm-wide risk assessment was in place using a template provided to the SRA.

The seriousness of the conduct was referenced in the SRA Enforcement Strategy, noting that such persistent regulatory breaches potentially harm public interest and confidence in the legal profession.