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AML AUDIT SOLUTIONS


Offering Regulated Firms for Help with AML Compliance, Including Policy
Templates, SRA AML Audits, AML Policy Updates.

Policy Templates SRA Audit Help

1125 SRA-Regulated firms have used Lexsure’s services to assist them in AML
Compliance

6986 AML Policy paragraphs have been downloaded in the last 12 months

HOW DO THE SRA SELECT FIRMS FOR AN AML AUDIT?

The SRA approach to Anti-Money Laundering (AML) supervision is based on
assessing risks.

The SRA approach to Anti-Money Laundering (AML) supervision is based on
assessing risks.

The SRA prioritises visits to firms categorised as high risk, but also inspect
those with low and medium risk ratings. It's important to note that selection
for an AML audit does not automatically indicate that your firm is perceived as
highly susceptible to money laundering activities.

In identifying high-risk firms, the SRA refer to the relevant sections of the
Office of Professional Body Anti-Money Laundering Supervision (OPBAS) source
book. Additionally, they may utilise information in their possession when
evaluating the risk level of firms.

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WHEN WILL THE SRA FIRST MAKE CONTACT WITH MY FIRM CONCERNING AN AML AUDIT?

Do not panic. The SRA are not in the habit of unexpectedly appearing at a law
firm’s offices. Typically, the SRA will schedule visits with you with ample
preparation ...

Do not panic. The SRA are not in the habit of unexpectedly appearing at a law
firm’s offices. Typically, the SRA will schedule visits with you with ample
preparation time, opting for a date further in the future.

Rather than feeling anxious, consider the visit as a chance to organise your AML
procedures. Contact our help desk. If you're aware that your records are not
current or worry that recent legislative changes (and their subsequent
amendments) may have caused oversights, there's still time to address any
issues.

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WHAT DO THE SRA ASK FOR AHEAD OF AN AML AUDIT INSPECTION?

Prior to the audit, the SRA will request the submission of the following
documents: Your firm's Anti-Money Laundering (AML) risk assessment, as mandated
by Regulation 18 of The Money ...

Prior to the audit, the SRA will request the submission of the following
documents:

 * Your firm's Anti-Money Laundering (AML) risk assessment, as mandated by
   Regulation 18 of The Money Laundering, Terrorist Financing and Transfer of
   Funds (Information on the Payer) Regulations 2017 (MLR 2017).
 * Your firm's risk assessment concerning proliferation financing, as required
   by Regulation 18A of the MLR 2017. This assessment may either be a distinct
   document or integrated into your firm's comprehensive risk assessment.
 * AML policies and procedures of your firm in accordance with Regulations 19 to
   21 of MLR 2017.
 * Your firm's client AML risk assessment template.
 * Copies of any audits conducted on your firm's policies and procedures under
   Regulation 21 of MLR 2017, including recommendations or subsequent actions
   resulting from them.
 * Records of AML-related training, as stipulated by Regulation 24(1)(b) of MLR
   2017.
 * A roster of fee earners handling work within the scope of MLR 2017.
   Additionally, we will require matter lists to facilitate the selection of
   files for review.
 * If feasible through your case management system or processes, a list of open
   matters identified as high risk.
 * Completion of a brief questionnaire detailing the services provided by your
   firm.

You must ensure these documents are provided within a 10-day timeframe

Generally known as a practice-wide risk assessment (PWRA), this serves as the
foundation for your AML controls and is imperative for compliance with the SRA
Standards and Regulations.

While initiating with a AML policy template is permissible, customisation based
on the specific risks facing your firm is essential. Ensure that your AML Policy
document undergoes regular reviews in line with your policy. To assist in this
regard you may wish to consider subscribing to an AML Policy update service.
Such services provide periodic updates, often in light of recent
cases,legislation, or emerging best practice/behaviour. Additionally, your risk
assessment should incorporate guidance from the Legal Sector Affinity Group
(LSAG), if it doesn't already.

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WILL THE SRA AML AUDIT CONSIDER OUR FIRM'S SOURCE OF FUNDS AND WEALTH
PROCEDURES?

You will need to provide evidence and document any perceived risk in this
regard.

…

You will need to provide evidence and document any perceived risk in this
regard.

For instance, are you requesting clients to provide court orders from a divorce,
probate, or a completion statement from a related or recent sale? Relying solely
on a client's verbal confirmation about selling a house and using the proceeds
for another transaction is not considered good practice.

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WHAT HAPPENS DURING THE VISIT OF OUR OFFICES DURING A SRA AML AUDIT ?

During a visit by the SRA will interview some fee earners and review a random
selection of ongoing and historic files. Where staff members are absent (e.g.
due to ...

During a visit by the SRA will interview some fee earners and review a random
selection of ongoing and historic files. Where staff members are absent (e.g.
due to holiday), it's necessary to arrange for someone to step in.

During file reviews, the SRA will focus on aspects such as:

 * A random selection of both live and archived files, along with the accounts
   ledger.
 * Ts and Cs as well as client care letters
 * E-verification results and the handling of failed or referred matters.
 * ID as well documentation of any face to face meeting (inc remote meetings).
 * Google or other search engine adverse findings.
 * Company searches—reporting anomalies related to beneficial ownership to
   Companies House through a discrepancy report.
 * Evidence of the SOF and SOW.
 * Relevant Defence Against Money Laundering (DAMLs) or Suspicious Activity
   Reports (SARs).
 * Client and matter risk assessments, and how risk is managed throughout the
   transaction life cycle, including post completion

We recommend informing all staff about the visit beforehand. Individuals
selected for discussion can range from partner level to junior staff. It's vital
that your MLRO (Money Laundering Reporting Officer) is also accessible for
interviews with the SRA audit.

All staff should be well-prepared to articulate the firm's AML controls
confidently. Firms do of course need to do ongoing training. The expectation and
preparation for an SRA meeting should be raised annually.

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WHAT HAPPENS AT THE END OF THE SRA AML AUDIT?

The SRA offer various measures based on the compliance status of a firm post
audit :

Guidance Issuance:

The SRA offer various measures based on the compliance status of a firm post
audit :

Guidance Issuance:

Applicable when a firm complies with the required standards in the regulations.
This includes cases where minor adjustments are needed or where sharing best
practices can enhance compliance.

Letters of Engagement:

 * Applicable for partially compliant firms.
 * Issued when some elements of a firm's controls require improvement, yet there
   is evidence of good practice.
 * Involves engagement with firms to assist in refining processes and achieving
   full compliance.

Implementation of a Compliance Plan:

 * Implemented for partially compliant firms with broader concerns.
 * This plan is initiated when multiple elements of a firm's controls need
   improvement, or there are significant non-compliance issues.
 * Outlines a series of actions with specified timelines to guide firms toward
   full compliance with regulations.

Referral for Investigation:

 * Reserved for non-compliant firms.
 * Triggered by issues such as failure to conduct customer due diligence (CDD),
   absence of a firm-wide risk assessment, outdated policies, or inadequate
   staff training on regulations.
 * Involves referring the firm for investigation, potentially leading to
   regulatory sanctions.
 * In some cases, a compliance plan may be established to support the firm in
   meeting its obligations.

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