Is Your Law Firm Ready for an SRA Desk-Based AML Investigation?

With the SRA continuing their drive to ensure the legal industry is up to date with the requirements to comply with the Anti Money Laundering (AML) regulation, firms must be ready to respond to the SRA within 21 days of receiving a request for information.

Firms are being selected at random and as noted, the time to provide the requested information is short so being prepared and ready is essential.

Failing to ensure your firm is fully compliant with the requirement of the AML regulations will put the COLP, MLCO and firm generally at risk. If you receive an enquiry the minimum you will be asked to produce will be: –

• The firm’s risk assessment is required by Regulation 18 of the AML regulations.
• The firm’s policies and procedures to manage AML and ensure there is firm-wide and consistent implementation, as required by Regulation 19.

This request may at first blush seem simple but for a firm to comply with the AML regulations is not straightforward as there are a number of absolute requirements that firms must adhere to or their internal processes will not meet the requirements and that could and is likely to lead to a further investigation and potential sanctions.

The SRA has been very clear for the past 18 months about their drive to review the industry’s approach to AML and firms who fail to meet the standard have little or no excuse.

Firms are well-advised that policies must be up to date and staff training must be up to date and the firm must be able to evidence the application of their procedures and processes on an ongoing basis.

If you believe your firm may be at risk or you simply wish to confirm your firm is achieving the required standard, at The Strategic Partner, we offer a range of solutions which include: –

1. Review – A review of the firm’s approach to regulation and compliance including AML procedures. The output of which provides the firm with a written gap analysis and solutions to remedy any issues. 
2. Training – to include: –
   1. AML Training for ALL staff to meet the firm’s obligation to provide annual training.
   2. 1-2-1 training for the MLRO and MLCO on their obligations and requirements.
   3. Practical training for those involved in client onboarding to ensure their ID and AML checks are completed properly.
3. Auditing – Procedural, staff, systems and files to ensure the procedures are up to the required standard and being implemented at case level with a report of the outcome.
4. Solutions – Implementation of robust solutions to ensure the firm achieves compliance and then maintains compliance through the provision of ongoing support and assistance: –
   1. Risk Regulation & compliance Service including AML 
   2. Risk Compliance AML Guidance and Administration Service  

How we can help

The Strategic Partner provides essential support to law firms. We offer a range of services and consultancy tailored to the Legal sector including guidance and services for regulation and compliance including AML. We have gained a wealth of knowledge and experience in the overall management of law firms and work with them to achieve profitability, stability, and efficiency. Our goal is to become a valued and respected partner to our member law firms providing high-quality services and solutions at all times. If you would like to discuss how your firm approaches AML or if you would like to discuss any of our solutions you can call us on 020 3911 9710, email us at info@thestrategicpartner.co.uk visit our website and make an online enquiry.