‘Off-the-shelf’ AML policies put firms and clients at risk

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The SRA carried out 177 law firm inspections and 73 desk-based reviews between April 2022 and April 2023.

One in three (30%) of firms inspected were fully compliant with their AML obligations, with just over half (51%) partially compliant.

But the SRA found 19% of firms to be non-compliant, resulting in corrective or enforcement action.

Alongside the Solicitors Disciplinary Tribunal (SDT), the SRA has:

  • submitted 24 suspicious activity reports to the National Crime Agency relating to assets totalling more than £75 million
  • levied fines totalling £137,402
  • suspended one individual and placed controls on employment on another

Common compliance issues

Although most firms take their AML responsibilities seriously, the SRA criticised what it sees as a “tick-box” mentality in some firms.

The SRA warned about the use “off-the-shelf” AML polices not tailored to firms and suggested that it will take further action to counter this risk.

Common AML breaches included:

  • lacking or inadequate AML policies and procedures
  • non-compliance with firm-wide risk assessments
  • failure to carry out robust client and/or matter risk assessments
  • inadequate identification and…

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