How do the SRA decide which CQS firms to inspect?

The SRA adopt a risk-based approach to AML supervision.

The SRA visits a greater number of firms classified as high risk, while also conducting visits to low and medium-risk firms. It is important to note that a visit does not automatically imply that your firm is deemed high risk for potential money laundering activities.

To determine the firms the SAR classify as high risk they assess the pertinent sections of the Office of Professional Body Anti-Money Laundering Supervision (OPBAS) source book, which can be found at this link.

The regulator may also utilise the information within their possession regarding firms as they assess their level of risk. Nevertheless, the classification of a firm as high risk is not determined by a single factor.

Your firm will be asked, as part of the audit, for your AML Policy. CQS firms should have a policy as part of their Core Practice Management Standard policies.