Tag: Client Matter Risk Assessment
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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…
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Client matter risk assessment: Balancing compliance with conveyancing momentum
I recently joined a roundtable discussion with several MLROs to dive into the evolving world of Client Matter Risk Assessments (CMRAs). The conversation moved quickly past the “tick-box” mentality, focusing instead on how forward-thinking firms are reframing these assessments as continuous strategic assets rather than administrative hurdles. Here are the three biggest takeaways from the…
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The FCA is Coming: Why Your Next AML Audit is the Most Critical One Yet
A “changing of the guard” is underway in the world AML supervision. As recently reported by the Law Society Gazette, the UK government is moving toward a single supervisory model, with the FCA set to take over AML oversight from the SRA and other professional bodies. For many law firms, the reaction has been a…
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Why the SRA’s 2025 AML Crackdown is a Direct Threat to Your Lender Panel Status
For many law firms, receiving a fine resulting from an SRA AML Audit is seen as a big disciplinary blow, a public “black mark” and a hit to the profit and loss account. However, as we move through 2025 and into 2026, a much more clinical and commercially devastating threat has emerged. The real danger…
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SRA Cracks Down on Financial Crime: Whiteheads Case Study
The Solicitors Regulation Authority fined Whiteheads Solicitors £2,584 plus costs for failures in compliance with anti-money laundering regulations. Key issues included inadequate client risk assessments and poor scrutiny of fund sources. This case underscores the necessity for law firms to ensure rigorous application of AML policies to avoid penalties.