AML Firmwide Risk Assessment Case Study: F703A-05465-74E1C

Publication Date
2024-05-08

The Solicitors Regulation Authority (SRA) conducted an audit on a law firm, evaluating its adherence to compliance requirements. During the Anti-Money Laundering (AML) inspection, it was found that the law firm did not have the required policies, controls, and procedures in place, despite being subject to the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017. The SRA urged the law firm to implement these procedures without delay, and the law firm subsequently adopted compliant AML policies in November 2022.

From June 2017 to November 2022, the law firm failed to conduct adequate client and matter risk assessments. The assessment process implemented in November 2022 was found to be in compliance with the applicable regulations. The audit revealed that clients and matters were not being risk assessed adequately, as no documented assessments could be found during file reviews.

The law firm admitted to failing compliance with the regulations during the specified period. Following the inspection, actions were taken by the law firm to rectify these inadequacies through external assistance and it is now compliant with the regulations. The law firm has cooperated with investigations, and there was no evidence of harm to consumers or a high risk of repetition of these issues .