SRA AML and counter-terrorist financing risk assessment
SRA AML and counter-terrorist financing risk assessment

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • SRA AML and counter-terrorist financing risk assessment
  • Background
  • UK national risk assessment
  • Risk factors
  • What next?

The SRA’s Anti-money laundering and terrorist financing risk assessment sets out the key money laundering and terrorist financing risks for solicitors.

This Practice Note explains the background to the anti-money laundering and terrorist financing risk assessment, conducted and published by the SRA under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, which sets out the key money laundering and terrorist financing risks for solicitors. Here we explain its key findings and what publication of the SRA risk assessment means for you.

Background

Law firms and other entities caught by the MLR 2017 are at the bottom of a risk assessment pyramid:

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The SRA is the relevant supervisory body for the purpose of the MLR 2017.

When conducting your risk assessment, you must take account of the SRA's own risk assessment together with any guidance or other information published by the SRA, Law Society, etc.

The MLR 2017 require anti-money laundering (AML) supervisory authorities to identify and assess the international and domestic risks of money laundering and terrorist financing to which those relevant persons for which it is the supervisory authority are subject.

The SRA risk assessment published in March 2018 is the first AML sectoral risk assessment published by the SRA. The SRA says it will refresh it on a regular basis to keep up-to-date with