In the same week that the government acknowledged the regulations should be changed, a total of three conveyancing firms were fined by the Solicitors Regulation Authority for AML breaches.
A firm based in South Yorkshire was fined £23,549 for failing to meet the requirements of the MLRs 2017, placing them alongside dozens of firms who have also recently been fined five-figure sums.
Commenting on the investigation, the SRA released a statement claiming to have reviewed six of the firm’s live client files, finding that none of them contained client and matter risk assessments (CMRAs).
The SRA wrote: “It appears that no risk assessment took place at the start of each matter (or monitoring throughout), to show the file handler had considered the risks of both the client and matter and therefore documented the correct level of customer due diligence.”
“In an email from the firm dated 20 December 2024, it was explained that some of the fee earners were not in the habit of completing a CMRA in every instance and that the firm had failed to detect this shortcoming.”
SRA AML CLAMPDOWN ON LAW FIRMS
Despite bringing itself into compliance by training its staff accordingly and confirming that all files contained a client and matter risk assessment, the SRA stated that the nature of the misconduct at a firm that undertakes the majority of its work in conveyancing was concerning.
It also fined a Greenwich-based firm:
- £9,179 – and a central London-based recognised sole practitioner,
- £9,656 for AML breaches.
The firm based in Greenwich is now understood to have failed to have in place
- a firm-wide risk assessment between 2017 and 2021,
- policies, controls and procedures between 2017 and 2021,
- non-compliant PCPs between 2021 and 2024,
- inadequate client and matter risk assessments between 2021 and 2024,
- customer due diligence/enhanced customer due diligence on individual matters.
The central London-based firm, on the other hand, failed to have a firm-wide risk assessment in place from 2017 to 2022.
Source: here.
AML SUPPORT SOLUTIONS LONDON
Don’t be next! If your firm undertakes conveyancing work, now is not the time to be taking any chances with your compliance.
Regardless of whether your firm offers conveyancing services or not, all firms must demonstrate and uphold high standards in their AML systems and processes, as well as in their management and supervision. This also involves outlining how the firm operates, including the conduct of staff in accordance with established policies, controls, and procedures.
At the Regulation & Compliance Office, we can offer a number of outsourced support solutions, including:
- Regulation & Compliance Service – Our Risk Management Assessment Service has been specifically designed to review and update a firm’s approach to risk and compliance management.
- MLR 2017 Regulation 21 Independent Audit – A review of the firm’s approach to regulation and compliance, including AML procedures, with the audit meeting the requirements of Regulation 21 of AML 2017. The output provides the firm with a written gap analysis and solutions to remedy any issues and ensure compliance.
- AML Training Courses – Our Typical AML Training Includes:
- AML Training for ALL staff to meet the firm’s obligation to provide annual training.
- One-to-one training for the MLRO and MLCO on their obligations and requirements.
Contact Us Now
Call us now on 0203 985 8550, email us at info@regulationandcomplianceoffice.co.uk or make an online enquiry here.
