AML Firmwide Risk Assessment Case Study: CA89B-5FCF1-16F25

Publication Date
2024-03-22

Based on the provided instructions, the case study has been modified to reflect the actions taken by the SRA, omitting specific names, paragraph numbers, and unnecessary sections. Here's a summary of the document after applying the changes:


The SRA conducted an audit of a law firm to assess compliance with anti-money laundering regulations. The audit identified deficiencies in the firm's procedures, specifically regarding their Firm Wide Risk Assessment (FWRA) and Policies, Controls, and Procedures (PCPs). The FWRA was not in place from June 2017 to April 2020, and the PCPs were not compliant from June 2017 until December 2022. Furthermore, the firm failed to conduct Client Matter Risk Assessments (CMRA) as required between June 2017 and April 2022.

The law firm's non-compliance with the anti-money laundering requirements was serious, involving breaches of regulatory obligations over a prolonged period. The firm had failed to adhere to prescribed guidance and notices meant to mitigate risks associated with money laundering.

The SRA decided to impose a financial penalty on the law firm due to the severity of the breaches. Nonetheless, mitigation factors were considered, such as absence of materialised harm, the cooperation and admissions by the law firm, and remedial actions that were undertaken.

The audit by the SRA highlighted the importance of maintaining robust compliance systems to uphold public trust and confidence in the legal profession.


This synopsis removes specific legal references and focuses on summarizing the SRA's actions and findings while adhering to the specified modifications.