SRA AML Training - Thematic Review

Staff are the first line of defence against criminals, so it’s vital to train them to identify money laundering and on how to report it internally. The SRA’s proactive inspections raised particular concerns around AML training, with 45% of firms found to be non-compliant in this area. This prompted the SRA to carry out a thematic review.

The SRA expects firms ‘to put in place a comprehensive AML training programme which is relevant to the legal sector and specific to their firm’. SRA AML inspections have long-included a review of AML training records. In a recent development, firms with on-site inspections are also required to provide the content of training so that the inspector can assess the quality of the training provided.

If you don’t know where to start, the thematic review provides guidance on what to include and suggested approaches, with a useful AML Training checklist.

Key points include:

• Firms shouldn’t rely on generic training and standard webinar packages so as to tick the training box. (One of our pet hates is hearing that a team has been ‘sheep-dipped’ through the AML training!). Whilst high-level standard training packages can be useful, staff should also receive bespoke training relevant to the risks individual firms face.

• It’s essential to provide AML training to fee earners on the firm’s own internal AML policies, controls and procedures, including their client and matter risk assessing process.
• Don’t just provide a single one-off session annually. Ongoing and additional training is important. Consider including ‘bite-size sessions’ to ensure engagement.
• Make AML training as interactive and engaging as possible, including incorporating real-life case studies, to help keep training relevant and interesting.
• Consider making some training department-specific to cover the specific risks which people face in their day-to-day role.
• The Money Laundering Compliance Officer should consider undertaking additional training. The thematic review found that where MLCOs had undertaken additional training, firms were almost 50% more likely to be compliant than those where MLCOs had not received additional training.

Enderley provides AML training, made bespoke to your firm. Do get in touch if we can help.