Category: AML Firmwide Risk Assessment
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Firmwide risk assessments: turn the SRA framework into a document that reflects your firm
A firmwide risk assessment (FWRA) should explain how your firm could be exposed to money laundering and terrorist financing, and what you do about those risks. It is not a generic AML statement or a form to complete once and file away. It is the firm-level foundation for your policies, controls and procedures, and it…
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The AML Evidence Chain: Why Every Document Must Tell the Same Story
AML compliance fails when risk assessments, policies and file records exist in isolation. A defensible framework requires every document and decision to connect.
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Firmwide Risk Assessment: Time for a Refresh?
For many firms, the Firmwide Risk Assessment is a document that sits in a digital drawer, updated only when the SRA sends a nudge. But as we move through 2026, the regulatory landscape has shifted. The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 have arrived, and with them, a new set of expectations that…
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Firmwide Risk Assessment Failures | SRA AML Fines
Recent SRA enforcement highlights the risks of static, generic or missing firm-wide risk assessments. The FWRA should reflect your practice and shape your AML procedures.
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The AML compliance gap no one wants to talk about
In the field of anti money laundering, many lawyers fall into the trap of conflating source of funds with source of wealth. They treat them as a single requirement when they are in fact two distinct obligations. One is a forensic look at a specific pot of money. The other is a holistic assessment of…
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The High Street Practitioner’s Guide to Surviving the FCA
The shift to FCA supervision for AML compliance demands small firms document their processes and justify decisions, moving away from reliance on personal relationships. Sole practitioners face increased responsibilities for compliance. Implementing efficient systems and tracking risks is essential to navigate regulatory scrutiny and demonstrate commitment to AML standards without overwhelming workloads.
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Mind the Gap: SRA Targets the “Disconnect” in AML Policies for 2026 Thematic Review
The SRA’s 2026 AML thematic review will scrutinize the effectiveness of firms’ AML Policies, Controls, and Procedures (PCPs). It aims to address the ongoing disconnect between established policies and actual practices. The review emphasizes the importance of independent audits and proactive compliance measures to strengthen AML frameworks and mitigate risks effectively.
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Navigating AML Compliance in 2025
As 2025 approaches, SRA-regulated solicitors face intensified AML compliance challenges, including increased audits, stricter penalties, and the need for enhanced due diligence. Firms must adopt proactive measures such as robust risk assessments, effective controls, and ongoing training. Leveraging technology and staying informed on regulations is crucial for maintaining compliance and protecting reputations.
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AML Firm-Wide Risk Assessment: The Foundation of Your AML Controls
A firm-wide risk assessment should explain the money laundering and terrorist financing risks your law firm faces and how it manages them. Here is what an effective FWRA needs to cover and how to keep it connected to your AML controls
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Example support call to AML Helpdesk
Law firm (sole practitioner CQS accredited) calls with AML concerns about a potential client. The client had a significant sum of money in an overseas account which was not in the client’s name. The firm made further enquiries with the client regarding the funds and requested additional evidence to satisfy source of funds/wealth requirements. The…