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Compliance Update July 2025
Can you believe we’re already over halfway through 2025? Time flies when you’re having fun in the legal compliance world! While some of us might be diving into pool floats and sunscreen this summer, we’re diving in headfirst to deliver this Q3 compliance update. Grab your iced coffee—it’s time for the latest scoop (and no, not the ice cream kind). New rules and guidance from SRA SRA Business plan: The SRA has been consulting on its 2025-26 business plan due to “unforeseen and changing priorities” since the original corporate strategy for 2023...
Trend in firms losing authorisation
We are noticing a trend of law firms encountering issues with their authorisation following changes to their management and ownership structures. This can have serious consequences for the business. We recently saw a case where a non-lawyer was issued a small number of shares in a ‘traditional’ recognised body law firm, which led to the loss of the firm’s authorisation and will require re-authorisation by the SRA. If you are appointing non-lawyer directors or shareholders (including entities) to a ‘traditional’ law firm, this will begin a...
SRA AML inspections – what will you have to provide?
The letters we are seeing from the SRA notifying firms that they intend to visit them to carry out an AML inspection appear to be asking for increasing amounts of information and documents. We thought it would be helpful to give you a heads-up and share this information with you….forewarned is forearmed and all that (although be aware that the list of what they request may change at any time). They will ask you to complete an AML Questionnaire, which includes questions about your firm (such as number of offices, percentage of work/ fee...
LSAG Guidance updated – April 2025
Summary of changes: (Please note that some of the wording in the Schedule didn’t make it into the body of the guidance as intended!) 4.2.2/ 6.16.2/ 6.18.1 & 6.18.2 – Beneficial owners: definitions changed in these sections to “more than 25%” as opposed to “25% or more” and correspondingly “25% and below” as opposed to “below 25%” (most other references to beneficial owners in the guidance already made this point, so this is clarification rather than big news). 4.7 – Economic Crime Levy: Further information and references the obligation to...
SRA AML & Sanctions questionnaire time… already!
The SRA has announced that they will again be running their AML and Sanctions data collection exercise this summer (in July rather than August/ September this year) and that it is a regulatory requirement to complete it. Further information, including various questions and answers and a specimen questionnaire (last year’s version!), can be found at: SRA | Firm anti-money laundering and sanctions data requirements | Solicitors Regulation Authority. Although the announcement refers to all firms within scope of the Money Laundering Regulations...
Sanctions: OFSI’s ‘key lessons’ and more
⚠️ Has your firm assessed your exposure to sanctions risks and put in place policies and procedures to mitigate these? ⚠️ If not, we strongly encourage you to do so in light of the increased focus on this area for law firms of all shapes and sizes. It seems likely that we will see an increase in fines imposed by OFSI (the Office of Financial Sanctions Implementation) and possibly OTSI (the Office of Trade Sanctions Implementation) over the coming months and years, which will likely include law firms (both in and out of scope of the Money...
Compliance Update April 2025
The days are getting longer and the daffs are blooming… it must mean that spring is here. So, with that, here’s a roundup of new guidance that the SRA’s sprung on us… New rules and guidance from SRA After last quarter’s plethora of SRA guidance notes and Warning Notices, the SRA appears to have taken a bit of a break from these, which will hopefully mean everyone has a chance to catch up on reading the backlog, particularly after a comment in their Professional Obligations Thematic Review in December that they expect firms/ solicitors to read...
Compliance Update January 2025
We kick off as ever with the latest roundup of new guidance from the SRA. Grab a cuppa ☕ and take a deep breath as there’s a fair amount to catch up on… New rules and guidance from SRA SRA Anti-money laundering report 2023-24: The SRA’s latest annual report on AML was published in October, and is worth a read by all firms in scope of the Money Laundering Regulations. With increased SRA resources since the last report, they’ve almost doubled their proactive AML engagements with firms, leading to significantly increased levels of...
Compliance Update October 2024
New rules and guidance from SRA It’s been a busy few months over at the SRA! Which in turn has meant a busy few months for us 😂 😎 We spent our summer assisting our retainer clients with their AML & Sanctions questionnaire which came out to all firms this Summer (we do hope you made the September 23rd deadline!). In addition to delighting law firms with this little treat, the SRA also published a number of warning notices & new guidance. 📆 Key deadline for October: don’t forget that the window for practising...
Compliance Update May 2024
New rules, guidance and warnings We kick off as ever with the latest roundup in the ever changing world of law firm anti-money laundering / financial crime updates: Some new countries were recently added (Kenya & Namibia) and removed (Barbados, Gibraltar, Uganda, United Arab Emirates) from the list of high-risk third jurisdictions. The next FATF plenary is likely to report any minute so it’s always best to refer directly to the most up to date list. We like to use the Law Society’s consolidated list so that it’s all in one nice neat place...