SRA AML Policies Review: Will It Reflect Lexsure’s Audit Findings?

The SRA is scheduled to present findings from its latest review of AML policies, controls and procedures in a webinar on 19 October 2026. The session will cover good and poor practice, giving firms an opportunity to consider how their own arrangements compare.

Details and registration are available through the SRA’s events page. Firms should select the session titled “AML policies, controls and procedures”.

Will the findings reflect what independent audits reveal?

Lexsure will be interested to see whether the SRA’s conclusions reflect those reached during the many independent AML audits it has carried out over the last 12 months.

An independent audit examines how a firm’s AML policies, controls and procedures operate in practice, helping identify areas where written requirements and everyday file handling may diverge.

The useful comparison will be between the SRA’s published findings and the evidence emerging from individual firms’ documents, file reviews and staff interviews. Until the findings have been examined, it would be premature to claim that they confirm Lexsure’s conclusions.

Policies need to be reflected in the files

A firm may have detailed policies but still struggle to demonstrate that staff apply them consistently.

Our analysis of AML failures despite existing policies illustrates why the existence of documents does not establish effective compliance on individual matters.

When reviewing the SRA’s findings, firms should consider practical questions:

• Do staff understand the procedures relevant to their work?
• Do client and matter risk assessments identify the actual risks?
• Does the file explain the scrutiny applied to source-of-funds evidence?
• Are concerns escalated and decisions recorded?
• Does supervision identify weaknesses and result in corrective action?

These are suggested questions for the firm’s own review, rather than a prediction of the SRA’s conclusions.

Connect the risk assessment with the controls

The firm-wide risk assessment should inform the AML procedures applied by fee earners. Changes in the firm’s clients, services, transaction patterns or delivery channels may require corresponding changes to those controls.

Our guide to the firm-wide risk assessment and its connection to AML controls explains why the assessment, policies and client and matter risk assessments need to work together.

A review should therefore examine consistency between the documents and the work undertaken, rather than treating each document as a separate compliance task.

Independent AML audits and up-to-date policies

Firms seeking independent scrutiny can explore Lexsure’s Independent AML Audit Service.

For support with maintaining documentation, firms can also:

• Explore Lexsure’s AML Policy Update Service.
• Browse the AML policies and procedures available from POLICYmonitor.
• Review the dedicated Sanctions Policy.

Suggested wording and templates need to be assessed and tailored to the firm. Keeping policies current should be accompanied by staff training, effective supervision and checks that the procedures are being followed.

Relevant amendments should be approved, communicated and tested, with responsibility allocated for addressing weaknesses.

Turn the findings into a documented review

After reviewing the webinar and any accompanying publication, identify which findings are relevant to your practice. Record the documents, procedures or training requiring attention, allocate actions and check implementation.

Where an independent audit has already identified similar weaknesses, consider whether the corrective action has been completed and whether its effectiveness has been tested.

For the wider compliance-officer perspective, explore the COLP & COFA compliance blog alongside the AML guidance on About Conveyancing.

This article reflects the position on 14 October 2026, before the scheduled SRA webinar. It does not summarise unpublished findings. Firms should assess subsequent publications against their own circumstances and applicable obligations.