AML Firmwide Risk Assessment Case Study: B237D-8D510-FC2B5

Publication Date
2022-08-25

The Solicitors Regulation Authority (SRA) conducted an investigation into the law firm and identified multiple compliance failures concerning anti-money laundering regulations.

The firm did not have a documented and compliant AML firm-wide risk assessment from June 2017 to February 2022, as required by Regulation 18(4) of the Money Laundering, Terrorist Financing, and Transfer of Funds Regulations 2017 (MLRs 2017). The firm also failed to update its anti-money laundering policies, controls, and procedures (PCPs) to mitigate the risks of money laundering and terrorist financing starting from June 2017.

Furthermore, the firm did not conduct adequate source of funds checks for a client in a conveyancing transaction completed in March 2018. The firm also neglected to conduct ongoing monitoring of the transaction as it progressed, as mandated by Regulation 28(11)(a) of the MLRs 2017.

Additionally, from October 2018 to July 2022, the firm did not nominate a money laundering reporting officer (MLRO), which is required by Regulation 21(3) of the MLRs 2017.

As a result of these findings, the law firm was directed to pay a financial penalty of £1,300.

The SRA's audit and investigation actions revealed significant lapses in the law firm's adherence to anti-money laundering regulations over several years, demonstrating the importance of regular compliance and monitoring activities within legal practices.

The SRA’s detailed findings and the resulting penalties illustrate the necessity for law firms to maintain robust and updated compliance mechanisms to avoid regulatory breaches and potential penalties.