The SRA has confirmed that its annual AML & sanctions data collection exercise will take place in July 2026, with the online portal opening on 29 June 2026.
The SRA has stated that this is a regulatory requirement and firms which fail to complete the exercise may face regulatory action.
The exercise is designed to help the SRA assess AML and sanctions risk across the profession and will require firms to provide information regarding:
- Work carried out within scope of the Money Laundering Regulations
- Any contact or involvement with the sanctions regime
- Suspicious Activity Reports (SARs) submitted to the NCA
Importantly, firms which are not involved in one or more of these areas are still expected to respond and submit a nil return where appropriate.
The SRA has also confirmed:
- Only certain role holders will be able to complete the questionnaire (for example COLPs, COFAs, MLCOs, MLROs and authorised signatories)
- Access will require a mySRA login and authentication app verification
- Firms should ensure their mySRA roles and login credentials are up to date before the portal opens
- Estimates will be accepted where precise figures are not available
- Not all firms will necessarily be contacted as part of this year’s exercise
The SRA has published a specimen questionnaire in advance to help firms prepare, (you can find the link to this halfway down their web page here) which is sensible given some of the information requested may not be readily accessible depending on how data is stored internally.
As always, firms should treat this exercise seriously. The SRA uses the information gathered to inform its risk assessment process, inspection activity and wider AML supervision approach.
We would strongly encourage firms to begin reviewing the specimen questionnaire now and consider:
- Whether the firm captures the required data
- Whether AML records are sufficiently accessible and accurate
- Whether sanctions exposure has been appropriately assessed and documented
- Whether the firm’s AML framework remains fit for purpose
If you would like support preparing for the exercise, reviewing your AML systems and controls, or carrying out an independent AML audit, please feel free to get in touch.