The Solicitors Regulation Authority (SRA) conducted an audit on the law firm and identified several compliance issues with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017) and other regulations. The investigation revealed that the firm did not have a documented Firm-wide Risk Assessment (FWRA) from June 2017 until around December 2022. Although the firm had documented policies and procedures, these did not include a tailored FWRA until May 2023.
The law firm also failed to maintain documented Policies, Controls, and Procedures (PCPs) between June 2017 and October 2018. Even by July 2023, the PCPs were updated but not comprehensive enough to fulfill mandatory regulatory requirements. Furthermore, in one instance, the firm neglected to perform adequate source of funds checks.
During the audit, the SRA noted admissions of these failings from the law firm, which acknowledged non-compliance with relevant regulations between June 2017 and November 2019 and onwards into July 2023.
Additionally, the collaboration of the law firm with the SRA during the investigation process and remedial actions taken to rectify these issues were acknowledged. The SRA audit underscored the need for appropriate documentation and controls to prevent potential misconduct, emphasizing the importance of adhering to legal and regulatory obligations to avoid risks such as money laundering and terrorist financing.