The AML Policy templates are a great starting point for ensuring that you meet your Solicitors Regulation Authority (SRA) obligations. Our comprehensive editable template policies and procedures provide a cost effective toolkit for achieving firm-wide compliance with SRA rules, anti-money laundering procedures. No subscription is necessary.
Lexsure have drawn on significant experience of preparing policies and precedent documents to create an off-the-shelf set of AML template policies and procedures for you to use in building your AML risk and compliance framework.
You will need to make amendments to the documents to ensure that it matches your particular circumstances. Regulators have found that just copying and pasting the example AML policy/procedures is normally a strong indicator of a weak compliance culture and of non-compliance in respect of anti-money laundering, combating terrorist financing and sanctions.
Inadequate AML policies and procedures are identified by regulators as a recurring issue in inspections, emphasising the importance of comprehensive and updated AML policies in discharging AML obligations.
The AML policy wording and procedures you adopt should apply a risk-based approach, taking into account the services you offer, your clients and the size and nature of your practice. It is important to note that SRA AML audits, including desk-based, inevitably involve reviews of a practice’s policies and procedures that take place as a precursor to an inspection, and therefore form part of the regulators inspections framework.
We have a variety of policy templates and AML policy update services available to purchase :
Lexsure is often asked if it is necessary to have an independent audit of policies, controls, and procedures (PCPs). The answer depends whether you are able to appoint someone within your practice that is independent of the AML PCPs and relevant work will depend on the size of the practice. Smaller practices are unlikely to be able to appoint an independent internal auditor, but should still maintain a schedule for the monitoring and review of PCPs.
One final note, please make sure that staff know and understand your firm’s policies, controls and procedures.