firm wide risk assessment
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Nine Years Without a Documented FWRA: What This SRA Fine Teaches
An SRA desk based AML review found that a small London practice had operated for almost nine years without a documented firm wide risk assessment and could not produce CMRA records on half the files examined.
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FCA Wants Partnership With Solicitors. It Will Still Expect Proof
The FCA says it wants partnership, proportionate supervision and less unnecessary paperwork. For law firms, that makes evidence of effective AML controls more important, not less.