In January 2024 alone, reports were published about the SRA taking enforcement action against 3 firms and 4 individuals for failure to comply with the Money Laundering Regulations 2017. The fines issued for these non-compliances total over £570,000 plus costs. The absence of staff training, or requirement to complete additional training, was noted in a number of these cases.
Many of the breaches resulting in enforcement action involved failures by the fee earners to conduct appropriate due diligence, adequately check the source of funds and/or wealth or recognise and report red flags. As highlighted by enforcement action being taken against individuals as well as firms, fee earners cannot hide behind their firm when AML failures occur and may be held personally accountable by the SRA for non-compliances with the MLR 2017.
This course will cover the following to assist fee earners in the application of AML in their casework.
- How to comply with your obligations and stay compliant
- Written CRA & MRA
- Client
- Booms
- Risks – what to consider?
- PCPs – CDD &EDD
- POCA / TA
- SOF and SOW
- On going monitoring
- Reporting to MLRO/MLCO
- Tipping off