AML Firmwide Risk Assessment Case Study: 2062F-65CB5-3FDF5

Publication Date
2024-05-23

The Solicitors Regulation Authority (SRA) undertook an investigation into a law firm beginning in March 2022. The investigation revealed that the firm had engaged in conveyancing transactions between 2011 and 2019 that fell under the Money Laundering Regulations 2007 and 2017. The firm failed to implement the necessary documentation and training required by these regulations, and it did not appoint a Money Laundering Reporting Officer as mandated.

Moreover, the investigation uncovered instances where the firm's client account was used to facilitate transactions that were not related to any legal services typically provided by solicitors, a practice that continued over an extended period. The law firm was found to have failed in various aspects, including not establishing adequate anti-money laundering policies, not conducting compliant firm-wide risk assessments, and not securing approval for its beneficial owners, managers, and officers.

The SRA determined that between April 2008 and November 2019, and up until April 2022, the firm committed multiple breaches of regulatory obligations. These lapses showed a pattern of non-compliance that the SRA deemed both serious and reckless, thereby affecting public trust and confidence.

For these reasons, the firm was directed to pay a financial penalty. Despite the severity of the non-compliance, the firm cooperated during the investigation and took steps to remedy its breaches.