Independent Anti-Money Laundering Advice and Audits
Anti-money laundering (AML) compliance is high on the SRA’s list of priorities. In 2020-2021, the regulator visited 69 firms as part of its rolling programme to assess AML compliance, finding only 16 fully compliant and 45 partially compliant. Eight firms were non-compliant and referred for investigation. has announced plans to increase the number of visits in 2022
Anti-money laundering (AML) auditing
Why is an independent AML audit important?
Of the 69 firms visited by the Solicitors Regulation Authority (SRA) in 2020-2021, 49 had not carried out an independent audit of their AML policies, controls and procedures, as required by the Money Laundering Regulations 2017. Further, none of those firms placed on a compliance plan by the SRA or which were subject to further SRA investigations had carried out an independent audit.
Independent AML audit services
Most smaller firms don’t have the internal resource for an independent audit, as this can’t be done by the MLCO, MLRO or anyone involved in AML compliance in the firm, and that is where we can help you.
At Enderley we recognise that an AML audit can be a daunting experience for everyone in your business. We’ve been auditing law firms for over 10 years. We’ve also been the subject of audits, so we know how it feels to be on the other side of the fence. Our aim is to deliver an audit that provides insight and proactive advice for your business.
What happens at an Enderley AML Audit?
We can carry out the audit remotely or on-site, to suit your time and budget.
Step 1: Document Review
The first step will be to review your key AML documents, including your AML Practice Wide Risk Assessment and AML Policy. We may also ask for access to your training records.
Step 2: Interviews
We will conduct an in-depth interview with your MLCO and MLRO, and shorter interviews with selected members of your team, testing their knowledge and understanding of the firm’s policies, controls and procedures.
Step 3: File Reviews
We will ask you for a matter listing and select a small number of files for review. We will be reviewing AML compliance only, so checking that due diligence procedures have been followed, including investigation of beneficial ownerships, source of funds and wealth evidence, client and matter risk assessments, and ongoing monitoring.
What happens after the AML audit?
Report on our findings
We will produce a detailed report for you, setting out our findings and any recommendations we have for improving your firm’s resilience to money laundering threats and its legal and regulatory compliance.
Follow through
We will advise you on implementation of our recommendations, and provide you with additional support if needed.
Anti-Money Laundering Essential Documentation
Are you confident that your firm’s AML Policy is entirely compliant?
Does your AML Practice Wide Risk Assessment accurately reflect the risks associated with your firm’s location, work types, client base, and other specific factors? Have you reviewed and updated it in the last 12 months?
60% of the AML policies, controls and procedures reviewed by the SRA during their 2020-2021 on-site audits were either not compliant or were partially compliant.
How can Enderley help?
We will review your current documentation and advise you of any changes needed. If we consider that you need completely new documents, we will draft them for you.
Anti-Money Laundering Training
We offer flexible, bespoke AML training for smaller law firms. We’ve developed online, interactive, trainer-led training, but we can also provide on-site face-to-face training at your offices if preferred. Through workshop-style sessions we encourage people to share their own experiences and insights with their colleagues and to relate broader AML issues to the firm’s AML Policy and Practice-Wide Risk Assessment.