Fraud panic sheet—law firms
Fraud panic sheet—law firms

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

  • Fraud panic sheet—law firms

    1. 1

      Preliminary screening

      1. 1.1

        Guidance

        It is important that certain types of fraud are reported and managed via the relevant dedicated reporting mechanism to ensure statutory protections are preserved, eg money laundering suspicions should be reported via the firm’s anti-money laundering process to ensure protection under the Proceeds of Crime Act 2002, whereas a person reporting suspicions of employee fraud should have the benefit of protection under the firm’s whistleblowing policy.

      1. 1.2

        Actions

        If the suspected fraud involves money laundering, terrorist financing, mortgage or property transactions, liaise with the [nominated officer OR MLRO] to determine whether a suspicious activity report is required.

        If there is a suspicion of bribery or corruption, liaise with [insert name or title of person in charge of anti-bribery process] pursuant to the firm's anti-bribery and corruption policy.

        If the suspected fraud may have been perpetrated by a member of staff, department or the firm itself, liaise with [insert name of person responsible for whistleblowing process] pursuant to the firm's whistleblowing policy

        If the fraud does not fall into any of the above categories and it involves client account money, continue to section 2.

    1. 2

      Assemble fraud response team

      1. 2.1

        Guidance

        Having undertaken preliminary screening, the first step is to assemble a team to manage and respond to the breach. This is likely to involve your COLP

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