- Publication Date
- 2024-03-14
In June 2017, the SRA's proactive AML team conducted a desk-based review of the law firm’s compliance with Anti-Money Laundering (AML) regulations, which highlighted several concerns. This prompted a referral to the SRA’s AML investigation team. The law firm subsequently received guidance to comply and by April and May 2023, had implemented a AML firm-wide risk assessment (FWRA) and Policies, Controls, and Procedures (PCPs) necessary for compliance.
It was determined that between June 2017 and April 2023, the law firm did not maintain a documented assessment of the money laundering and terrorist financing risks associated with its business operations as required by the MLRs 2017. Additionally, from June 2017 to May 2023, the firm failed to establish and maintain fully compliant AML policies, controls, and procedures to mitigate and effectively manage these risks and to regularly review and update them as stipulated by the MLRs 2017.
As a result, the law firm was found to be in breach of its regulatory obligations both prior to and after November 2019. The firm's conduct warranted serious consideration due to the prolonged nature of non-compliance, disregard for the SRA’s guidance and warning notices, and the potential harm to public interest and confidence in the legal profession.
Subsequently, the law firm was ordered to pay a financial penalty of £12,181. Several mitigating factors were taken into account, including the firm's cooperation with the SRA, the rectification of breaches, and the lack of evidence suggesting any actual harm had materialized.
The decision reflects the SRA's commitment to ensuring that legal firms adhere strictly to AML regulations, underscoring the significance of maintaining adequate and documented risk assessments and controls.