Former SRA regulatory manager launches free webinar on anti-money laundering compliance
A former regulatory manager at the Solicitors Regulation Authority (SRA) is hosting a free webinar to help law firms strengthen their anti-money laundering (AML) policies.
Michelle Clement (pictured) spent five and a half years at the SRA.
During that time, she carried out hundreds of AML inspections and desk-based reviews, and wrote the regulator’s guidance on client and matter risk assessments and on source of funds and source of wealth.
She has since launched her own consultancy offering AML policy support to firms.
The online session takes place on Thursday 26 November, from 12.30pm to 1.30pm.
Michelle will explain how the SRA assesses a firm’s risks and controls, and where large and small firms most often come unstuck.
Michelle said the firms she reviewed were generally well developed on paper, but weaknesses emerged when files were examined in detail and compared across a sample.
The most common issues she found were risk ratings with no recorded reasons, similar clients rated differently by different fee earners, supervision that took place but could not be seen on the file and assumptions of low risk based on how long a client had been with the firm.
She said that when the same issue appears across several files, it stops being an isolated problem and becomes a finding about the firm’s controls.
She suggests a simple test firms can carry out now.
They should pull five closed files across different fee earners and matter types, and read each one as a reviewer would.
Then they should ask whether someone who wasn’t involved could see why the risk rating was given.
She said: “A reviewer reads files cold, often months or years after a decision was made.
“If the reasoning is not on the file, it is not available to them. A policy says what should happen and the file shows what did, and the gap between the two is where most findings begin.”
The webinar comes as the SRA’s latest AML annual report highlights that many of the problems it identifies stem not from a lack of controls, but from the quality of those controls and how they are applied in practice.
