What are the UK AML requirements for law firms?
The UK’s Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR2017) transposed the requirements under the EU 4th AML Directive (4AMLD), which brought law firms into scope for the respective AML requirements as of 26 June 2017. In recent years, these requirements have been amended and guidance has been published to aid compliance with the evolving regulatory landscape.
The Solicitors Regulation Authority (SRA) have been very active in performing regulatory visits as well as reviews and thematic assessments to ensure the circa 7,000 law firms regulated by the SRA have adopted and maintained these AML requirements.
SRA reviews have demonstrated that many firms have not fully adopted or maintained all requirements, and may be missing key components of requirements, such as having appropriate policies and procedures in protect the firm from being used to facilitate money laundering (ML) or terrorist financing (TF) and having an independent audit of the AML programme and controls conducted.
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