- Publication Date
- 2024-02-02
In June 2023, the SRA assessed the law firm’s compliance in terms of money laundering, as the firm had been undertaking in-scope work (conveyancing) since 2016. The law firm took remedial action when alerted to the investigation. However, the investigation identified several areas of non-compliance before this point.
The law firm failed to establish and maintain appropriate and risk-sensitive policies and procedures between 2016 and June 2017. Additionally, from June 2017 to May 2023, the firm did not have a firm wide risk assessment in place, as required. During this period, the firm also failed to establish and maintain AML policies, controls, and procedures to mitigate and manage the risks of money laundering and terrorist financing, and did not regularly review and update them.
Between around 2018 and May 2023, the firm did not establish an independent audit function with the responsibility to examine and evaluate the adequacy and effectiveness of its AML policies, controls, and procedures. Furthermore, the firm did not conduct adequate client and matter risk assessments on 19 client files during the specified period.
The firm was directed to pay a financial penalty of £9,750. This decision was based on the firm’s continuous breach of regulatory obligations, evidenced by a persistent pattern of non-compliance. For an extended period, the firm failed to heed guidance and warning notices explaining the requirements and risks associated with non-compliance with anti-money laundering regulations. The firm's conduct was deemed serious, with potential harm to the public interest and public confidence in the legal profession. Mitigating factors included the firm's current compliance with the 2017 regulations, admissions made, and cooperation with the investigation process. These factors positioned the firm's conduct towards the lower end of the financial penalty bracket.