- Publication Date
- 2024-03-05
The Solicitors Regulation Authority (SRA) conducted an audit on a law firm to assess compliance with requirements under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). The SRA's Anti-Money Laundering (AML) Proactive Team identified concerns related to the firm's compliance with documented risk assessments, policies, controls, and procedures regarding money laundering.
Between June 2017 and March 2022, the firm did not maintain a proper risk assessment for money laundering and terrorist financing risks, as required by Regulation 18 of the MLRs 2017. Moreover, until September 2022, the firm failed to conduct an adequate firm-wide risk assessment. It was also found lacking in having fully compliant policies, controls, and procedures, with non-compliance continuing until April 2023.
In March 2022, the SRA provided guidance to aid in compliance, resulting in the implementation of proper firm-wide risk assessments by September 2022 and the establishment of compliant procedures by April 2023.
The SRA determined that the law firm's conduct breached its regulatory obligations, persisting beyond a reasonable timeframe and demonstrating non-compliance patterns that could harm public interest and confidence in the legal profession. Due to the severity of these issues, they were placed within a specific conduct band for financial penalties. This resulted in a financial penalty of £12,989.68.
The firm demonstrated cooperation with the SRA, remedied the breaches, and there was no evidence of actual harm materializing due to the misconduct. The SRA took these factors into account during the decision-making process.
This audit and consequent findings acted as a reminder and warning to maintain high standards of compliance to protect public interest and uphold the integrity of the legal services.