Tag: Client Matter Risk Assessment
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Independent AML Audit: Is Your Firm Prepared for the 2027 FCA Takeover?
Robust anti-money laundering (AML) controls are critical for law firms. The SRA emphasizes practical compliance over mere documentation. A Reg 21 Independent AML Audit is essential for assessing risks, due diligence, and governance. As scrutiny intensifies, firms should prioritize these audits to foster a culture of compliance and avoid FCA sanctions.
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Firmwide Risk assessment failures land more firms with AML fines
So far in 2026, SRA AML audits have continued to unleash a wave of Regulatory Settlement Agreements (RSAs), signaling a zero-tolerance approach to static, generic, or missing Firmwide Risk Assessments (FWRAs). The Cost of Non-Compliance In the first quarter of 2026, financial penalties for AML-related failures have reached record levels. Analysis of recent settlements reveals…
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Reg 21 Independent AML Audit : The Real Work Begins After
5 Immediate Actions for Law Firms Following a Reg 21 Independent AML Audit You’ve just crossed the finish line of your Regulation 21 Independent AML Audit. The report is in your inbox, and the temptation to file it away and return to “business as usual” is strong. However, the stakes for law firms have changed.…
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Lender panels and compliance audits: why preparation is your firm’s strongest defence in 2026
For many conveyancing firms, lender panel membership has long been treated as a stable and reliable part of the business. With CQS accreditation in place and a clean professional indemnity record, lender panel status often felt secure and rarely required active attention. That assumption is becoming increasingly outdated. In 2026, lender panel membership is no…
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The “FCA Effect”: Why Regulation 21 Independent AML Audits are No Longer Optional
For years, many UK law firms viewed Anti-Money Laundering compliance as a “lawyer-led” exercise, principled, interpretive, and often collaborative with supervisors like the SRA or CLC. However, the ground has shifted. With the recent announcement that the Financial Conduct Authority (FCA) is set to become the single AML supervisor for the legal services sector, the…
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The FCA’s High-Stakes AML Takeover of the Legal Sector
The transition from SRA to FCA oversight for AML represents an “architectural reset” of the UK legal regulatory climate. While the 2017 Regulations remain unchanged, the move to a “Single Professional Services Supervisor” replaces the SRA’s collaborative, guidance-based approach with the FCA’s assertive, data-driven enforcement. This shift aims to eliminate the fragmented supervisory landscape that…
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Regulation 21 Independent AML Audit: More Than a Regulatory Requirement
Following on from my recent blog on the evolving role of the MLRO, I realised I overlooked one critical component: the independent AML audit. The more I considered it, the clearer it became that this is not a supporting detail but something that deserves attention in its own right. Under Regulation 21 of the Money…
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MLRO: From Compliance Gatekeeper to Cultural Architect
The role of the Money Laundering Reporting Officer at a law firm often remains an additional task. It is a thankless, burdensome responsibility tacked onto an already busy fee-earning role. Historically, it was viewed as a “back-office” necessity; a hat to be worn only when a problem arose. Today, that dynamic has shifted. As regulatory…
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The Independent AML Audit; Why it Matters
Under Regulation 21 of the MLRs, UK law firms are required, where appropriate to the size and nature of the business, to establish an independent audit function. This is no longer a “check-the-box” exercise; it is a critical risk management tool. On the flip side, a poorly executed Independent AML Audit can lead to public…
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Client Matter Risk Assessment: Automation
The majority of law firms continue to use paper-based Client Matter Risk Assessments, but there is an inevitability regarding the shift from manual to automated processes. Even now, one could argue it is almost a regulatory necessity. As law firms navigate increasingly complex AML regulations and the prospect of the FCA as a regulator in…