A trio of fines for money laundering breaches handed down by the SRA at the end of April 2024 have highlighted the dangers of non-compliance by smaller and medium sized law firms. The fines total over £45,000 and in each of the three cases, basic money laundering due diligence was not done, or the correct policies and procedures were not put in place.
The decisions come as the SRA flexes its new fining powers, with at least ten decisions on AML breaches in the first quarter of 2024 alone. These cases saw fines of almost £170,000. With the trio of fines in April, the average AML fine for a small or medium size d law firm falls between £10,000 to £25,000.
The cases revolved around a failure to property conduct due diligence on clients and third parties, and failing to properly assess matter risks. Due diligence wasn’t done on funds coming from other jurisdictions and enhanced due diligence wasn’t done, nor was due diligence completed before accepting funds, and firm AML policies controls and procedures were not fully in place.
Continue reading