The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) came into force in June 2017. Law firms carrying out certain types of work are required to comply with these regulations, including conducting a AML firm-wide risk assessment to identify and assess risks of money laundering and terrorist financing.
The SRA asked these firms to complete a declaration, confirming that they have a compliant anti-money laundering risk assessment in place by January 2020.
The law firm failed to provide the required declaration until March 2021, which was found to be in breach of the relevant regulations.
The SRA directed the law firm to pay a penalty of £800.