- Publication Date
- 2024-03-19
The SRA's AML investigation team conducted an audit on the law firm to evaluate its compliance with the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017. The investigation identified significant discrepancies in the firm's required documentation and policies, prompting the need for an intervention by the SRA.
During the audit period from June 2017 to November 2023, it was discovered that the law firm failed to establish and maintain adequate firm-wide risk assessments (FWRA) and appropriate policies, controls, and procedures (PCPs). These findings emerged from a review initiated in November 2021, which highlighted the firm's non-compliance with the regulations, despite being provided guidance by the SRA. The firm initially attempted updates to its documentation in September and October 2022, but these efforts still fell short of regulatory requirements until compliant documents were finally in place by November 2023.
As a consequence of these regulatory breaches, the firm was fined £19,482. The penalty was determined by the seriousness of the firm’s conduct, which was characterized by prolonged non-compliance and a lack of adherence to SRA's guidance and warnings. The misconduct posed risks to public interest and undermined confidence in the legal profession.
The SRA considered mitigating factors such as the firm's cooperation during the investigation and its eventual rectification of non-compliance issues. Additionally, there was no evidence of material harm resulting from the firm's initial failings.