- Publication Date
- 2024-02-20
In March 2022, the SRA's Anti-Money Laundering (AML) Proactive Team conducted a desk-based AML review at the law firm to assess its compliance with the MLRs 2017. The firm had been involved in relevant activities since 2010. It was determined that the law firm did not have a compliant firm-wide risk assessment (FWRA) or policies, control, and procedures (PCPs) in place.
Additionally, it was revealed that four files within scope lacked client or matter risk assessments. In January 2020, the firm had submitted an online declaration asserting MLRs 2017 compliance. This was completed by the compliance officer for legal practice (COLP) under the mistaken belief that compliance was achieved, which was not the case.
By April 2023, the firm provided a fully compliant FWRA and, by May 2023, submitted fully compliant PCPs to the SRA.
The SRA identified that the law firm failed to establish a firm-wide risk assessment from June 2017 to April 2023, as stipulated by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Furthermore, from June 2017 to May 2023, the firm did not have compliant policies, controls, and procedures as required by Regulation 19 of the MLRs 2017.
On four files, the law firm did not perform required client or matter risk assessments according to MLRs 2017 regulations. In January 2020, the firm provided inaccurate information to the SRA by declaring its compliance with a firm-wide risk assessment, despite this not being in place.