- Publication Date
- 2023-04-03
The Solicitors Regulation Authority (SRA) conducted an audit of the law firm and identified several breaches of the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017).
Since June 2017, the law firm failed to have a documented and compliant AML firm-wide risk assessment (FWRA) and did not adequately consider the SRA’s warning notice on firm-wide risk assessments.
The firm also failed to have in place compliant anti-money laundering (AML) AML policies, controls, and procedures (PCPs) to mitigate and effectively manage the risks of money laundering and terrorist financing. These failures were in breach of various principles and regulations.
The firm did not comply with the terms of a compliance plan agreed upon in June 2021 between the firm and the SRA. Consequently, the SRA imposed a financial penalty of £5,000 on the law firm.
In light of the firm's continued failure to comply with the MLRs 2017, certain conditions were imposed on its authorization. The firm was required to produce a revised and compliant FWRA and update its AML PCPs to ensure compliance with the regulations. The firm was given one calendar month to provide evidence of compliance.
The long-standing and persistent nature of the firm's non-compliance indicated systemic issues within the firm. The SRA determined that conditions were necessary to monitor compliance and prevent future breaches, ensuring the firm adheres to the MLRs 2017. The conditions imposed were deemed reasonable, proportionate, realistic, and measurable.