The SRA continues to levy large fines on regulated firms who have been in long-term breach of their obligations under the 2017 money laundering regulations. It is not clear whether the decision stems from an SRA AML Audit having been carried out.
Fairhurst Menuhin & Co in Essex was fined £23,930, 2% of its turnover and close to the maximum the SRA can hand out, for not having proper AML policies, controls and procedures in place between 2017 and 2022.
In addition, the firm failed to carry out adequate client/matter risk assessments on six files, while it received funds on account on four matters before completing customer due diligence.
Its mitigation was co-operation with the SRA and having “some arrangements in place for managing the risk of money laundering prior to August 2022, including staff training and email reminders regarding ID/AML checks”.
The firm had also taken steps to remedy the harm and there was no evidence that actual harm had materialised. No mention was made to the absence of an AML Firmwide Risk Assessment.
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