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AML – Policies, Procedures and Control

The LSAG AML Guidance document sets out a range of the key policies that underpin your firms legal AML requirements. By both being aware of and having an understanding of these principles and the reasons behind them, you can ensure that you are constantly addressing your obligations and working towards ensuring that your practice is compliant.

Governance Within Your Firm

The governance requirements of the guidance relate to the structure of your firm, and how the framework of people within it should operate. The main key takeaways from this are that;
  • Owners, managers and officers must be SRA approved
  • An MLRO must be appointed to deal with reporting and disclosures.
  • An MLCO must be appointed where the size and nature of the firm deem it necessary to deal with the compliance of the practice
  • Operational, day to day activities can be delegated from the Board to the MLRO but the responsibility and accountability cannot.
  • All procedures, policies and controls must be approved by the Board and documented, with adequate time and resources allocated to this

The Risk Based Approach

Your firms attitude to risk and how it is identified, assessed and handled is arguably the biggest factor in ensuring you are compliant within the scope of AML. By operating with a risk based approach dependant on your exposure, it means that you can focus your efforts and resources on the highest level of risk within the business, which in turn can help to minimise your overall compliance costs and burden.

As part of this risk based approach, the guidance states that you must complete a firm wide risk assessment which can help to identify where you are most at risk. This assessment will also feed directly into the policies, controls and procedures that your firm will require in order to demonstrate its compliance with the regulations. You must also evidence that you are continuing this risk based approach on a client and individual matter level, by undertaking a written risk assessment following a clearly documented procedure for each new client or matter that is undertaken.

This blog has been written by Intuitive Legal, a compliance consultancy providing law firms with support and advice on all aspects of SRA Regulations. https://www.linkedin.com/company/intuitivelegal/

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