You should ask staff to sign a declaration confirming they have read, received and understood your policies and procedures and, if appropriate, attended the associated training. This

Law360, London: The worlds of art and terrorism may seem very far removed from each other; the traditional images of each are dramatically different. However, the 9 May 2025 guilty plea and conviction in Westminster Magistrates' Court of Oghenochuko Ojiri, an art dealer also known for his role in the television programme Bargain Hunt, has brought the risks into sharp relief.

Name of firm [Insert firm name] Name of role holder [Insert role holder name] Reports to [Insert, eg COLP] Role type (full-time/part-time/contractor) [Insert type] If a contractor role, length of contract [Insert contract length] Primary location [Insert the primary location for this role—if there is a requirement for the role holder to regularly spend time in multiple locations, eg in each regional office, it is worth making sure this is made clear] Remote/hybrid/office-based? [Insert] Date role commenced [Insert date] Length of probation period [Insert probation length] End of probation review date [Insert date] Role summary The compliance [manager OR assistant] role provides: • effective risk management • up-to-date regulatory compliance awareness • guidance on best practice within the firm Liaises with The compliance officer for legal practice (COLP), the compliance officer for finance and administration (COFA), [the lead for [Lexcel OR CQS OR SQM OR WIQS] quality standards, Complaints partner/officer, the nominated officer and the money laundering compliance officer (MLCO)]. The compliance [manager OR assistant] will work closely with the heads of the various support functions and fee-earning departments to manage risk in the firm and to ensure compliance with SRA requirements and other relevant legislation and procedures. Key responsibilities General risk management Objectives

A member of the firm responsible for compliance in accordance with rule 8.6 of the SRA Authorisation Rules

1 Compliance officer for finance and administration (COFA) details Name of firm [Insert firm name] Name of COFA [Insert name] Reports to [Insert name] Full time/part time [Insert] Details of any other roles held within the firm [Insert] Date appointed by the firm [Insert date] Date approved by the SRA [Insert date] 2 Role summary 2.1 Lead [insert firm name]’s [global] SRA Accounts Rules compliance strategy and culture. 2.2 Take all reasonable steps to ensure [insert firm name] and its managers, employees or interest holders comply with any obligations imposed upon them under the SRA Accounts Rules. 2.3 Ensure a prompt report is made to the SRA of any serious breach of the SRA Accounts Rules and other reportable matters which apply to [insert firm name] and its managers or employees. 3 Job description/role profile 3.1 Compliance culture and strategy 3.1.1 Promote a culture of regulatory compliance within [insert firm’s name] in relation to the SRA Accounts Rules. 3.1.2 Inform and advise [insert firm’s name] and its managers and employees of their obligations under the SRA Accounts Rules and other applicable regulation and legislation. 3.1.3 Co-operate with the SRA and act as the contact point for the SRA on Accounts

A member of the firm responsible for compliance with regulatory arrangements in accordance with rule 8.5 of the SRA Authorisation Rules.

1 Compliance officer for legal practice (COLP) details Name of firm [Insert firm name] Name of COLP [Insert name] Reports to [Insert name] Full time/part time [Insert] Details of any other roles held within the firm [Insert] Date appointed by the firm [Insert date] Date approved by the SRA [Insert date] 2 Role summary The obligations in this section and the remainder of this job description, do not apply in relation to the SRA Accounts Rules. 2.1 Lead [insert firm name]’s [global] compliance strategy and culture. 2.2 Take all reasonable steps to ensure [insert firm name] and its managers, employees or interest holders comply with the SRA regulatory regime and other relevant statutory and regulatory obligations. 2.3 Ensure serious compliance breaches and other reportable matters are properly and promptly reported to the SRA and/or any other relevant regulator. 3 Job description/role profile 3.1 Compliance culture and strategy 3.1.1 Promote a culture of regulatory compliance within [insert firm’s name]. 3.1.2 [Develop and manage [insert firm’s name]’s global compliance strategy.] 3.1.3 Inform and advise [insert firm’s name] and its managers and employees of their obligations under the SRA Standards and Regulations and other applicable regulation and legislation. 3.1.4 Co-operate with the SRA and act as the contact

This Checklist is designed to help you determine whether you have the systems in place to comply with regulatory requirements that apply to law firms in relation to the appointment of compliance officers and reporting compliance breaches. It reflects requirements of the SRA Standards and Regulations together with the SRA’s enforcement strategy and its thematic review of compliance officers. It should be read in conjunction with subtopics: COLP and COFA and Compliance breaches. It covers requirements in relation to both compliance officers for legal practice (COLPs) and compliance officers for finance and administration (COFAs). Appointment and approval of compliance officers (COLP and COFA) The requirements set out in the table below apply to the firm. Requirement Compulsory or recommended Comments (if any) ☐ Ensure that, at all times, your firm has an individual who is designated as its:—COLP—COFA Compulsory for authorised bodies regulated by the SRA, ie:—a recognised body (ie lawyer-owned firm)—a licensed body, eg an alternative business structure (ABS) or a multi-disciplinary practice (MDP)—a recognised sole practiceSRA Authorisation of Firms

This Practice Note provides guidance on the role and responsibility of compliance officers in law firms, ie the compliance officer for legal practice (COLP) and compliance officer for finance and administration (COFA). It reflects obligations in the SRA Standards and Regulations, SRA guidance on the responsibilities of COLPs and COFAs and the SRA’s thematic review of compliance officers. It includes a summary of the regulatory obligations in relation to reporting compliance failures to the SRA but there is a separate Practice Note providing more detailed guidance on reporting compliance failures—see: Breach reporting—law firms. Requirement to have compliance officers An authorised body must at all times have an individual who is designated as its COLP and an individual who is designated as its COFA, and whose designations the SRA has approved. An authorised body is: • a recognised body (ie lawyer-owned firm) • an alternative business structure (ABS), or • a recognised sole practice regulated by the SRA. The primary legislation and SRA Standards and Regulations differ on the titles of the compliance officer roles, but this

Power to make a compliance order A court imposing a confiscation order under the Proceeds of Crime Act 2002 (POCA 2002) has additional means by which it can seek to enforce that order. Upon making a confiscation order the court must consider whether to impose a 'compliance order' upon the defendant. It must also consider whether to impose one at any later time (while the confiscation order is still in effect) on the application of the prosecutor. A compliance order is an order that the court believes is appropriate for the purpose of ensuring that the confiscation order is effective. In considering whether to make a compliance order the court must, in particular, consider whether any restriction or prohibition on the defendant’s travel outside the UK ought to be imposed. Beyond this, there is no clear indication in the legislation of what is meant by making a confiscation order effective and whether there is any limit on the nature or type of order which may be made. Any person affected by the compliance

This Practice Note considers compliance planning for law firms. It explains whether law firms should have a compliance plan and, if so, what you may wish to include. It reflects the Solicitors Regulation Authority (SRA) Standards and Regulations. See also Precedent: Compliance plan—law firms. Is a compliance plan compulsory? Firms that have or wish to obtain Lexcel accreditation must have a risk management policy that includes a compliance plan. There is, however, no direct requirement in the SRA Standards and Regulations for law firms to have a compliance plan. This contrasts with the previous SRA regulatory regime, where the SRA clearly expected firms to have a compliance plan—the guidance notes to the SRA Authorisation Rules 2011, stated: ‘what needs to be covered by a firm’s compliance plan will depend on factors such as the size and nature of the firm, its work and its areas of risk’. This has not been carried across to the SRA Authorisation of Firms Rules in the SRA Standards and Regulations. It is therefore a matter for firms whether they choose

1 General information Date of annual review Person(s) conducting annual review [Insert date] [Insert names(s)] 2 Review and findings Item reviewed Outcome Does your Compliance plan accurately reflect your current compliance arrangements? ☐  Yes ☐  No (set an action point at 3 below) Does your Compliance plan correctly identify your COLP and COFA (and, if appropriate, their deputies)? ☐  Yes ☐  No (set an action point at 3 below) If you have appended a Register of compliance