In addition to regulatory obligations requiring all firms to provide regular Anti-Money Laundering (AML) training to all relevant employees, it has long been established that staff awareness is a crucial control for AML and counter terrorist funding (CTF). A recent thematic review by the Solicitors Regulation Authority (SRA) highlighted the importance of implementing robust AML training programmes tailored to the specific risks and requirements faced by legal professionals. The review also emphasised the SRA’s expectations for best practices and how training should be conducted.

The review – Anti Money Laundering Training – Thematic Review – was conducted to better understand how firms were complying with the requirements of regulation 24 MLRs and to identify examples of good and poor practice.

Key findings of the review included:

• Where money laundering compliance officers (MLCOs) had undertaken additional training, firms were around 50 per cent more likely to be compliant compared with firms where the MLCO had not undertaken any additional training.
• Training could be too focused on the regulations and thus what staff should do to remain compliant. The SRA shared concerns that this misses an opportunity to impress upon staff why having good anti-money laundering processes is important. This could be combatted by having interactive training with real-life case studies.
• A number of firms have recognised the need for on-going training, rather than one-off sessions, and that people learn in different ways.
• Firms should not rely purely on external providers – while generic training can be a good place to start, it’s unlikely to mesh with all of the risks that individual firms face. Some firms are now asking providers to develop bespoke training for them.
• Providers have also flagged this as a challenge – firms are buying standard packages to tick the training box rather than making sure what they do is relevant for them.

Failing to adhere to the AML regulations, including mandatory training requirements, can and will have severe consequences for firms. Non-compliance will attract negative attention from the SRA and other organisations such as your insurer. Furthermore, under the Proceeds of Crime Act 2002 (POCA) and Terrorism Act 2000, staff members could face criminal penalties if they are found to be involved in money laundering or terrorist financing.

You can access the full report, along with further guidance materials, here: Anti-Money Laundering Training – Thematic Review

Bespoke AML Training Programmes

At the Regulation and Compliance Office (RACO), we understand the unique needs of law firms when it comes to AML training. Our bespoke training programmes, delivered live, are designed to provide practical insights, real-world examples, and interactive learning experiences that resonate with legal professionals. By partnering with us, law firms can access specialised training solutions that align with the specific needs of the firm and its regulatory obligations.

Our core AML training courses include:

• Anti Money Laundering Training – The Basics – Course Length: 1-2 Hours

This course is prepared for all staff within a firm. It will provide an overview of the AML rules, establishing the core features and requirements for the firm and its staff. This course will provide sufficient information for everyone to understand their role in preventing money laundering and fraud. It should be used as part of your firm’s annual AML training to meet your regulatory requirements.

• Anti Money Laundering Training – The Detail – Course Length: 3-4 Hours

This is a detailed course for fee-earning staff, supervisors, and other staff involved in the AML process. It goes into detail on the AML regulations and highlights the requirements of a firm and its staff to protect themselves, and when and how they need to take action. The course also includes further elements, such as understanding source of funds and source of wealth, along with managing the enhanced due diligence process. We will discuss the implications of non-compliance and the actions to take when the firm faces potential or actual money laundering issues. We will also discuss auditing requirements and supervising the firm generally from an AML perspective.

• MLCO & MLRO Masterclass – Course Length: 3-4 Hours

A detailed course prepared for Money Laundering Compliance and Reporting Officers.

These roles are critical for protecting the firm, and failure to comply can lead to serious sanctions, including criminal prosecution. The MLRO and MLCO must be aware of their obligations and those of their staff. We will discuss and demonstrate the actions you must take and the detailed reasons why, and help implement a robust process within the firm that provides full but proportionate protection.

Access our full range of training programmes here: Training Courses for Law Firms

Reach Out to RACO

For more information on the Regulation and Compliance Office and how we can assist with your training requirements and accelerate your risk management, compliance and regulation, call us on 0203 985 8550 or email us at info@regulationandcomplianceoffice.co.uk