- Publication Date
- 2024-03-22
In June 2017, the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 came into force, requiring compliance from law firms engaging in specific areas of practice. These firms were obligated to implement compliant Policies, Controls, and Procedures, as well as conduct comprehensive client matter risk assessments to mitigate risks associated with money laundering and terrorist financing.
The SRA's Anti-Money Laundering Proactive Team conducted a desk-based AML review of the law firm in October 2021 to evaluate its adherence to these regulations. It was discovered that the firm did not have appropriate policies, controls, and procedures in place and failed to conduct adequate client matter risk assessments across four files.
Between June 2017 and September 2022, the firm maintained non-compliant Policies, Controls, and Procedures, contrary to the requirements of the Money Laundering Regulations 2017. This oversight persisted despite regulatory changes introduced in November 2019.
Consequently, the firm was directed to pay a penalty due to the seriousness of its conduct, which compromised regulatory obligations, risked public interest, and could potentially undermine public confidence in the legal profession. Although the firm admitted to its failures, cooperated with the investigation, and took steps to remedy the breaches, the severity of the infractions warranted a financial sanction.
The reporting of these matters focused on ensuring compliance with anti-money laundering legislation and safeguarding the integrity of legal services without emphasizing specific regulatory references.