- Publication Date
- 2024-02-05
The Solicitors Regulation Authority (SRA) conducted an audit of the law firm's compliance with the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). The investigation found that the law firm did not have a compliant AML firm-wide risk assessment (FWRA) or policies, controls, and procedures (PCPs) in place.
The relevant lawyer, who served as the law firm's compliance officer for legal practice (COLP), completed an online declaration in January 2020, mistakenly believing the firm was compliant with MLRs 2017 when it was not. The law firm could not provide evidence of any training given to the staff undertaking ‘in-scope’ work.
Despite providing some PCPs to the SRA in February 2023, these were not fully compliant until December 2023. The firm did not have a compliant FWRA until November 2023.
The findings of the investigation included:
- Between June 2017 and November 2023, the law firm failed to have in place a AML firm-wide risk assessment (FWRA) as required by Regulation 18 of MLRs 2017.
- Between June 2017 and February 2023, the law firm lacked the necessary AML policies, controls, and procedures (PCPs) as required by Regulation 19 of MLRs 2017.
- Between February 2023 and December 2023, the law firm had AML policies, controls, and procedures that did not meet the requirements of Regulation 19 of MLRs 2017.
On January 2020, the law firm provided the SRA with inaccurate information by making a declaration that its FWRA met the requirements of Regulation 18 of MLRs 2017. Between July 2017 and January 2021, the law firm failed to take appropriate measures to ensure that all relevant employees received anti-money laundering (AML) training as required by Regulation 24 of MLRs 2017.
As a consequence of these findings, the law firm was directed to pay a financial penalty.