On 7 May 2019, the Solicitors Regulation Authority (SRA) published its latest Anti-Money Laundering Thematic Review, focusing on firms offering trust and company services.
While many firms were fully compliant with their anti-money laundering (AML) obligations, the SRA had substantial concerns about a significant minority and referred 26 firms into its disciplinary processes as an outcome of the review.
The referrals were for breaches of the Money Laundering Regulations 2017 (MLRs) and no evidence of actual money laundering or intentional involvement in criminal activity was found at any firm.
The SRA suggested that its findings may indicate issues with the policies and procedures adopted by the firms and fee earners’ understanding of AML.
What can I do?
It is clear from the review that the SRA has (rightly) set a high level of expectations for regulated professionals’ knowledge of the AML framework.
- expect the SRA to go in to detail during visits
- build a culture of compliance throughout the firm, including among fee-earners
- tailor your processes to your firm’s individual risk profile
- make sure processes are detailed and updated regularly to reflect any changes you make to your risk assessment.
You should also use the contents and results of the review as a guide to what the SRA might expect from you during a thematic review or regulatory visit.