AML Firmwide Risk Assessment Case Study: CC9A0-0405F-FA36B

Publication Date
2021-10-18

The 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), which took effect in June 2017. These regulations mandate that law firms involved in certain activities must perform a risk assessment to identify and evaluate the business's exposure to money laundering and terrorist financing, known as the AML firm-wide risk assessment.

In January 2020, the SRA requested that all relevant firms submit a declaration affirming their compliance with having a AML firm-wide risk assessment addressing anti-money laundering. The law firm in question failed to provide the necessary declaration until April 2021, in violation of specific regulatory requirements governing firms.

The SRA decided to impose a financial penalty of £375 on the firm.