AML Firmwide Risk Assessment Case Study: C2F4E-9A6BD-96748

Publication Date
2024-03-04

The Solicitors Regulation Authority (SRA) conducted an audit and found that the law firm allowed its client account to be used as a banking facility for two clients between December 2021 and March 2022. This constituted a breach of relevant regulatory rules.

In several client files, the relevant lawyer failed to conduct adequate customer due diligence, source of funds checks, ongoing risk assessments, and maintain proper documentation. Additionally, the lawyer conducted a reserved legal activity without appropriate supervision.

During the period from December 2020 to January 2022, the law firm lacked a compliant firm-wide risk assessment and failed to ensure the implementation of necessary policies, controls, procedures, and the appointment of a money laundering reporting officer.

As a result, the SRA directed that a financial penalty of £18,750 be paid. The conduct was considered serious due to repeated misconduct, failure to comply with anti-money laundering legislation, misuse of the firm's bank account, and potential harm to public interest and confidence in the legal profession.

The relevant lawyer admitted the misconduct early in the process and cooperated with the SRA to remedy some of the effects, ensuring that the firm now adheres to compliant procedures and has appointed necessary supervisory roles.