1. Introduction: National Law Firm Fined for Failing to Comply with AML Regulations
A large national law firm has been fined over £100,000 plus £1,350 in investigation costs by the Solicitors Regulation Authority for failing to comply with anti-money laundering (AML) regulations. The fine, the fourth largest ever sanctioned by the SRA, was imposed despite no evidence of money laundering or financial crime. During the investigation, the SRA identified several areas of concern in relation to the firm’s compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles 2011, and the SRA Code of Conduct 2011.
2. SRA Decision – Agreement
The specific concerns were related to three conveyancing transactions carried out between October 2017 and March 2018. Two transactions involved property purchases worth £3.2 million and £550,000 on behalf of a limited company, while the third transaction involved a property purchase worth over £3 million on behalf of a UK registered charity.
The SRA acknowledged that the firm had adequate procedures and controls in place but failed to follow them in these specific matters. However, the SRA emphasised that there was no evidence of harm caused by these failures. A representative from the firm stated that they self-reported the potential breaches to the SRA in 2019 and have since made substantial improvements to their AML processes. These improvements include a more rigorous centralised client onboarding process, revised policies and procedures, and ongoing investment in training and education across the business.
You can read full details on the decision here: https://www.sra.org.uk/consumers/solicitor-check/508761/
3. Guidance for Law Firms
This recent case highlights the critical importance of complying with regulatory obligations and conduct requirements, especially for firms and their staff who are dealing in transactions deemed as high risk, such as property.
At The Strategic Partner, we appreciate that keeping pace with regulatory expectations and meeting the requirements is essential but time consuming and often confusing. Our services are designed to provide firms, employees, and their MLRO, COLP, and COFA with the comfort of knowing that even in the busiest of times, you remain compliant and can evidence that you are. Our objective is to empower firms to effectively manage risk, compliance, and regulation, allowing them to focus on delivering exceptional service to their clients.
We can offer expert guidance and support, including:
- Risk Management and Compliance Review – A review of the firm’s approach to regulation and compliance to include all regulatory requirements and AML procedures. The output of this provides the firm with a written gap analysis and solutions to remedy any issues.
- Risk Assessment Service and Independent AML Audit – A review of the firm’s approach to regulation and compliance to include all regulatory requirements and AML procedures. The output of this provides the firm with a written gap analysis and solutions to remedy any issues.
- 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 provides the firm with a written gap analysis and solutions to remedy any issues and ensure compliance.
- Training and Education – We offer customised training programs to educate your staff on AML regulations, source of funds and source of wealth enquiries, risk assessment, and suspicious activity detection. Our training ensures that your team is equipped with the knowledge and skills to fulfil their compliance responsibilities.
- 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.
- Ongoing Compliance Support – Our experts provide ongoing support and guidance, keeping you up-to-date with the latest AML regulations and best practices. We offer regular compliance reviews, advice on complex cases, and assistance with regulatory reporting requirements.
4. Packaged Compliance Solutions
Our flagship compliance products are designed to give law firms cost-effective solutions that maintain an ongoing relationship across a 12-month period and beyond. You can view the 2 packaged services by clicking the following links and viewing our detailed product brochures:
- Risk, Regulation and Compliance Service (including AML)
- Risk, Compliance, AML Guidance and Register Administration Service
5. Get in touch with The Strategic Partner
For more information on The Strategic Partner and to discuss how we may be able to assist in