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SRA Fines Firm for not Fulfilling AML Obligations
June 30, 2022

A Midlands practice has been sanctioned by the SRA in another clampdown on failures with anti-money laundering regulations. Several shortcomings were identified, which resulted in the firm being fined £2,000 plus £1,300 costs.


Following the investigation, it was found that the firm had no compliant AML policies, controls, and procedures until February this year, despite having declared in 2020 that its risk assessment met the required standards. The SRA investigation also found that the firm’s policies lacked accurate information and had out-of-date guidance and links, with references to staff who had left and mention of superseded regulations.


Other failings included insufficient measures to ensure staff were made aware of the relevant rules and, in one instance, failure to complete adequate checks on a source of funds when £115,000 was received into the account and returned to sender following an aborted transaction.

The SRA said the sanction must create a ‘credible deterrent to others’ and signify to the public and legal sector the consequences of failing to comply with AML rules. There was no evidence of harm to consumers, or third parties and the SRA noted the firm’s help throughout the investigation, the remedies already carried out and remorse shown for its actions.


The latest fine is another example of how the SRA is persistent in its willingness to penalise firms and individuals who have not fulfilled their AML and regulatory obligations.


Fulfilling AML Obligations

Increasing numbers of firms are being asked to demonstrate their understanding of the requirements of the regulations and, importantly, evidence their compliance through the provision of documents and submit to files audits and staff interviews. At The Strategic Partner, we have worked with and assisted many firms in this enquiry process and continue to do so.

For many firms, dealing with this in-house without sufficient understanding, resource or time can be highly challenging to supervisors, compliance officers and their business, as compliance with the AML regulations is not as simple as it may first seem. Expert advice and guidance is often essential to ensure your firm achieves a compliant status and maintains it.


Fast Track, Cost Effective and Robust Compliance Solutions inc AML Compliance

The Strategic Partner’s packaged compliance solutions for law firms enable our clients to achieve a compliant status, and we continue to work with them on an ongoing basis to ensure they stay compliant. This includes compliance with the AML Regulations 2017.

Our solutions allow owners and staff to focus on services for their clients and running the firm knowing that their AML requirements are taken care of.


Our focus is to ensure each firm that works with us operates in a fully compliant environment and stays there. Through achieving this, the compliance officers in the business can be assured and confident that their obligations are being met, enabling them to focus on other areas of the firm.


Our Risk, Regulation and Compliance Service, including AML provide firms with a robust approach to Regulations, Compliance and risk management, giving the compliance officers peace of mind that the requirements of the regulator are being met on an ongoing basis and can be evidenced. External expert support will enhance the core strategies for firms with an internal team or person allocated to managing regulation and compliance.

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


Our Regulation and Compliance Services for Law Firms including training and AML


Regulation 21 AML 2017 Independent Audit – A review of the firm’s approach to regulation and compliance to include AML procedures with the audit meeting the requirements of Regulation 21 of the AML 2017. The output of which provides the firm with a written gap analysis and solutions to remedy any issues that rise and ensure the firm is compliant, see our brochure.


Training – Our typical AML Training includes:

  • AML Training for ALL staff to meet the firm’s obligation to provide annual training.
  • 1-2-1 training for the MLRO and MLCO on their obligations and requirements.
  • Practical training for those involved in client onboarding to ensure their ID and AML checks are correctly completed.

File Revies/Auditing – At TSP we engage with firms undertaking files reviews where we consider procedure, 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.

Our Packaged Compliance Solutions – Implementation of robust solutions to ensure the firm achieves compliance and then maintains compliance through the provision of ongoing support and assistance: –


Risk Regulation & compliance Service including AML  – Our Risk, Regulation and Compliance Service (including AML) has been designed to provide law firms of all sizes with a compliant environment. We provide you with policies and procedures that are bespoke to how your firm works, whilst drawing your attention to any gaps in your risk and compliance activities.

We work with firms of all sizes and types, from partnerships to ABSs, high street firms, and multinational firms. Each firm is different, and whilst there is a commonality of regulation and expected standards, it is essential to recognise how a firm implements compliance to tailor the solution to each firm’s working practices.


Risk, Compliance, AML Guidance and Register Administration Service – Running a compliant law firm is not just about implementing a set of policies and procedures; the obligations of the Compliance Officers stretch way beyond this, as there is an ongoing responsibility to manage, maintain and monitor the application of the firm’s compliance strategy.


The Strategic Partner’s Risk, Compliance, AML Guidance and Register Administration Service is an outsource solution providing all staff with access to an experienced and knowledgeable Compliance Manager for guidance and ensuring the regulatory requirement active management of the firm’s registers is met.

We would be pleased to discuss your current approach to regulation and compliance and how our services will assist you in ensuring your firm is protected. Often expert advice and guidance is essential to ensure your firm achieves a compliant status and maintains it.



For more information about our Regulation and Compliance Services (including Anti Money Laundering), you can call us on 0203 911 9710 or please email us at info@thestrategicpartner.co.uk.


You can read and download the PDF version of this article here. 

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