- Publication Date
- 2024-03-01
The audit by the SRA revealed several findings concerning the law firm's compliance with anti-money laundering regulations. In March 2023, the SRA's Anti-Money Laundering (AML) Proactive Team carried out a desk-based review to evaluate the firm's adherence to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). The review identified that the law firm failed to conduct client/matter risk assessments for five assessed files. The firm acknowledged that no such assessments were completed before March 2023.
The investigation found the firm's omission of required risk assessments constituted non-compliance with certain regulatory obligations. As part of the sanction, the law firm was directed to pay a penalty amounting to £23,035.50. Several factors contributed to determining the level of the fine, including the absence of significant harm, admissions by the firm, cooperation with the SRA, and actions taken by the firm to remedy the breaches.
The firm’s conduct was categorized as serious due to its breach of regulatory obligations, which persisted for an unreasonable duration and indicated a pattern of non-compliance. The firm bore sole responsibility for its conduct, which held potential for serious detriment to public interest and diminished confidence in the legal profession.
Upon reviewing the facts, the SRA decided on the appropriate measures and concluded the audit with the firm being placed within a specific conduct band concerning its financial penalty. This action was influenced by the proactive compliance steps taken by the firm prior to the review, which were factored into the final penalty assessment.