- Publication Date
- 2023-12-14
The audit conducted by the Solicitors Regulation Authority (SRA) identified several areas of concern regarding the law firm's compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017). The investigation revealed deficiencies in the firm's firm-wide anti-money laundering risk assessment and its anti-money laundering policies, controls, and procedures (PCPs).
The SRA’s inspection began following a proactive anti-money laundering (AML) desk-based review. In 2022, the SRA's AML Proactive Supervision team highlighted multiple AML control failings, which led to the case being escalated to the AML Investigations team. During this review, it was found that the firm had been using a client and matter risk assessment as its FWRA up until February 2022, which did not meet the requirements set under the MLRs 2017.
In February 2022, the law firm updated its AML firm-wide risk assessment to a comprehensive document, which satisfied the SRA’s AML Proactive team upon subsequent review. Additionally, the firm acknowledged that its PCPs drafted in February 2022 were initially non-compliant. Following further guidance, the firm provided an updated version of its PCPs in January 2023 that complied with the regulations.
By failing to comply with the MLRs 2017, the law firm admitted to these contraventions from June 2017 until January 2023. The investigation therefore concluded with the SRA issuing a financial penalty, recognizing the firm's cooperation in rectifying its AML documents and efforts to ensure full compliance.