Anti-money laundering (AML) services
Protect your law firm from financial crime
Money laundering is a global issue that enables criminals to disguise illicit financial gains as legitimate income. Through sophisticated methods, these funds are filtered into seemingly legal assets such as businesses, properties, or bank accounts. In some cases, laundered money is even used to finance terrorism, making it a critical concern for regulators and businesses alike.
With an estimated £100 billion laundered annually through the UK, and 4,500 organised crime groups operating within the country, tackling financial crime has never been more important. The National Crime Agency (NCA) and regulatory bodies continue to tighten compliance measures to safeguard businesses and the economy.
Law firms, accountancy practices, and businesses dealing with financial transactions must have robust AML procedures to prevent exploitation by criminals. The Solicitors Regulation Authority (SRA) has intensified its focus on AML compliance, ensuring firms assess and mitigate risks effectively. With the introduction of the Economic Crime and Corporate Transparency Act (2023), the SRA now has expanded powers to enforce compliance, including unlimited fines for breaches. This underscores the urgency for businesses to implement effective AML strategies.
Here at Enderley we can help law firms and accountancy practices protect themselves and remain compliant with the Money Laundering Regulations 2017 in a variety of ways.
Some kind words we have received from our clients recently post SRA inspection...
[The SRA AML inspection] went exceptionally well. The [SRA outcome] letter was received recently and there are no follow up issues, once again thank you for your kind assistance throughout this stressful task.
Just to say I had a glowing report on Friday with no further recommendations. [The SRA inspector] was happy with all the policies that were in place and on file. Thank you for your help and assistance.
I had a call from the SRA investigator this morning to run through a few points from their investigation and I am pleased to say that … we have passed !!! The success is largely due to your firm’s assistance Anne so thank you to all who helped
Key anti-money laundering documents
We help law firms write and review their Firm Wide Risk Assessment and AML PCPs to ensure they comply with the Money Laundering Regulations 2017, Legal Sector Affinity Group Guidance 2023, and SRA Guidance, as follows:
Client and Matter Risk Assessment
We can provide you with an up-to-date compliant Client and Matter Risk Assessment, with guidance on how to use it effectively.
We’ll also train your team on how to complete the Client and Matter Risk Assessment if needed!
Firm Wide Risk Assessment (FWRA)
Do you have an up-to-date Firm Wide Risk Assessment? Are you confident that it complies with all the requirements of Regulation 18 and would pass an SRA AML inspection? Have you reviewed it recently?
If the answer to any of these questions is ‘no’, we can help. We’ll draft a FWRA for your firm or review and update your existing FWRA.
We’ll start with a meeting to get to know more about your firm and send you a questionnaire to complete.
Based on the information you’ve given us, we’ll draft a FWRA and send it to you for review.
AML Policy Controls and Procedures
Does your firm’s AML Policy comply with Regulation 19? And is your Client and Matter Risk Assessment as robust as the SRA Guidance requires?
If you’re concerned AML PCPs may be out of date, we’ll review them. If they just need tweaking, we’ll update them for you; if they’re way off the mark, we’ll draft new ones for you.
Regulation 21 Independent AML Audits
Our AML audits follow broadly the same format as SRA AML inspections, but we typically speak with more people and review more matter files to cover as many risk areas as possible.
What happens during an AML audit?
Document review
We’ll do this ahead of the main audit. We’ll ask you to send us:
- Firm Wide Risk Assessment
- AML Policy, Controls and Procedures
- Template client and matter risk assessment
- The firm's AML training records
We’ll assess each document against the requirements of the Money Laundering Regulations 2017 and the Legal Sector Affinity Group Guidance 2023.
Interviews
We’ll start by interviewing the Money Laundering Reporting Officer (MLRO). We’ll also want to speak to the Money Laundering Compliance Officer (MLCO), COLP, COFA and the Head of Conveyancing (if your firm does property work), plus a cross-selection of your team including fee earners, support staff and accounts personnel. We recommend a good number of interviews across the firm to check that procedures are being applied consistently and identify any issues.
File reviews
At the start of the audit, we’ll ask you for a matter listing and select files for audit. File reviews will focus on AML aspects of the file – client due diligence, beneficial ownership, source of wealth and funds checks etc. As with interviews, we recommend review of a representative sample of files across all work types in scope.
Closing meeting
with the MLRO and other key stakeholders to discuss our main findings.
Written report
Within 10 days of completing the audit, we’ll provide you with a detailed written report. This will identify areas where procedures are working well, and those where there they are not working so well, with clear and justified recommendations for improvement.
If the firm is subsequently notified of an SRA audit, our report will provide evidence that the audit took place.
Follow up meeting
Once you’ve had time to read and consider our report, we’ll arrange a Teams call to discuss it and advise you on implementation of the recommendations. And if you need further support, we’ll provide it.
Will the AML audit be office based?
The AML audit can be on-site, remote, or a hybrid of the two.
If the audit is done remotely, we’ll need access to your case management system and we’ll use Teams for interviews.
How much does an AML audit cost?
We’ll provide you with a fixed fee, but the precise cost depends on a number of factors, including:
- On site or remote
- Number of people to interview
- Number of files to review.
Anti-money laundering training
Your team is the firm’s first line of defence against money laundering, and they need the tools to recognise it. The Money Laundering Regulations 2017 also require firms to provide regular AML training to all relevant employees. You can read more about our AML training and our pricing here.
