- Publication Date
- 2024-03-14
The SRA undertook an audit of a law firm's compliance with anti-money laundering (AML) regulations. This audit, performed by the SRA's proactive AML team, was part of a desk-based review conducted in 2023. During this review, the SRA identified several compliance issues related to the firm’s documented firm-wide risk assessment (FWRA) and its policies, controls, and procedures (PCPs) regarding money laundering and terrorist financing risks.
As a result of these findings, the matter was referred to the SRA’s AML investigation team, which provided the firm with guidance to assist in achieving compliance. Following this, the firm implemented a FWRA and updated its PCPs in April and May 2023 respectively.
The SRA found that from June 2017 until April 2023, the firm did not have a properly documented assessment of the risks associated with money laundering and terrorist financing as required by regulations. Moreover, from June 2017 to May 2023, the firm failed to establish and maintain fully compliant PCPs, and was also found to have inadequately reviewed and updated them regularly.
As a consequence of these failures, the SRA decided to impose a financial penalty of £12,181 on the law firm. Additionally, costs totaling £1,350 were also ordered to be paid by the firm.
The audit and subsequent sanctions highlight the importance the SRA places on adherence to AML requirements. The firm was found to have ignored the SRA’s guidance and warning notices for a substantial period, heightening the risk due to the large portion of in-scope conveyancing work. Despite these challenges, the law firm cooperated with the SRA and took steps to remedy the breaches, ensuring no actual harm occurred.