- Publication Date
- 2024-02-05
In June 2017, the law firm received a review from the SRA’s Anti-Money Laundering (AML) Proactive Team as part of a routine compliance assessment against the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. It was found that the firm did not have a compliant firm-wide risk assessment (FWRA) or the necessary policies, controls, and procedures (PCPs) in place.
During January 2020, the law firm had inaccurately declared to the SRA that its FWRA complied with the regulations, which was incorrect at the time. This declaration was made by the compliance officer for legal practice (COLP), who mistakenly believed in the firm's compliance status. Additionally, it was observed that the firm had been unable to provide evidence of any AML training being given to its staff involved in ‘in-scope’ activities.
By February 2023, the firm provided some PCPs to the SRA, but these measures only achieved full compliance by December 2023. A compliant FWRA was put in place by November 2023. Consequently, the SRA decided to impose a financial penalty of £3,203.20 on the firm.
Due to a significant pattern of non-compliance, and despite this being framed in conduct band C, the financial penalty was mitigated owing to the firm's later cooperation and compliance efforts. Therefore, the firm was positioned at the lower end of the fine bracket for having addressed the issues raised and engaging constructively with the SRA during its investigation.