Regulatory and Compliance Training & Consultancy

SRA Anti-money Laundering Clampdown

March 2019

The SRA have recently put solicitors' firms on notice that they will be carrying out rigorous checks on law firms to make sure they are meeting their anti-money laundering obligations.

The SRA have said they will be writing to an initial sample of 400 firms asking them to demonstrate that they are in compliance with the Money Laundering Regulations 2017. In particular, the SRA have highlighted the importance of every firm in the regulated sector having in place a money laundering risk assessment with firms that are not compliant being subject to enforcement action and, where the circumstances warrant it, disciplinary action.

More than sixty cases involving money laundering concerns have been considered by the Solicitors Disciplinary Tribunal in the last five years. Those cases have resulted in more than 40 solicitors being struck off, voluntarily coming off the roll, or being suspended from practising

If you fall within the regulated sector, how would your firm measure up to the SRA‘s expectations? Can you answer ’yes' to the following questions?

• Have you appointed a Money Laundering Compliance Officer (this is not the same as a Money Laundering Reporting Officer) since the new money laundering regulations were introduced in June 2017?

• Have you undertaken a firm wide money laundering risk assessment since the new money laundering regulations were introduced in June 2017?

• Is the risk assessment in writing and reviewed at least annually?

• For each new matter, is a risk assessment undertaken to determine the extent of customer due diligence required?

• Is the risk assessment documented on the client matter file?

• Does the firm have an up to date anti-money laundering policy which is compliant with the Money Laundering Regulations 2017 ?

• Have all relevant staff, including support staff where appropriate, received anti-money laundering training in the last two years?

If you have answered ‘no’ to any of the above questions, you may benefit from some assistance from us. Whether it is in-house anti-money laundering training, reviewing and updating your anti-money laundering policies and procedures or even undertaking a full SRA Compliance Health Check, we can help. For more information about a bespoke in-house training course for your firm please contact Richard Lane by calling now on 0330 223 5346 or by e-mail to info@lfpro.co.uk.

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