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AML compliance during SRA crackdown

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Recent SRA AML audits reveals a pattern of non-compliance with AML obligations among many firms. With this concern in focus, the SRA is contemplating fixed penalties for non-compliance. Law firms must now review and update AML processes diligently to avoid disciplinary measures, reputational harm, and hefty penalties.

This comes at a time when the SRA are carrying out an extensive and ongoing programme of audits into firms’ AML compliance. This includes desk-based AML assessments as well as targeted, in-depth onsite inspections.

  • If the firm should take on the relevant client or matter.
  • The level of due diligence to be conducted – where there is a situation that presents a higher risk of money laundering or terrorist financing, then enhanced due diligence (EDD) may need to be conducted.
  • Any other steps that should be taken to mitigate the risks posed.

Firms are mandated to have a written and bespoke fimwide risk assessment (FWRA). They must also have a complete and documented client and matter risk assessment (CMRA) carried out by the relevant fee earner to determine.

I am hearing a lot of disgruntled voices by law firms concerning SRA audits. As legal professionals one should have ability to research law, regulation, practice and procedures. The 2017 Regulations (as amended) are freely available online as is the Legal Sector Affinity Group guidance. There plent of guidance and support on the SRA website. If you don’t have the time or inclination to put things in order – engage the services an AML compliance consultant to help you meet what are government’s – not the SRA’s – requirements. There is SRA vendetta against the profession.



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