A little reminder that 29th June is fast approaching – the day that the SRA’s annual AML & sanctions data collection exercise opens, with data to be provided during July.
Compliance officers should be receiving (or already have received) an email from the SRA with further details (including a ‘log in’ link) about how to submit your collected data, so do look out for this (including in your junk mail into which SRA communications appear to be directed on an alarmingly regular basis!).
In the meantime, here are our top tips for preparing:
- Check that your mySRA login are correct and up to date and that your authentication app is set up correctly and working so you don’t face last minute panics not being able to login correctly.
- Ensure that a role holder authorised to submit the questionnaire will be available during July to do so (e.g. COLP, COLFA, MLRO, MLCO, authorised signatory).
- Remember that even if your firm is out of scope of the Money Laundering Regulations, you may still be asked to complete the sanctions section of the questionnaire, so keep an eye out for the email from the SRA. The SRA has explained that this year’s data collection exercise is ‘targeted’, but it is unclear what their ‘targeting’ involves.
- Whilst the questionnaire questions are the same as last year, they still involve the collection of a lot of data, so it is definitely worth having a look at the specimen questionnaire (here) well in advance of the date you propose to submit it so that you can start locating the relevant data/ ask the right questions of the right people.
- Ensure you have reviewed and updated your AML and Sanctions policies and procedures (including your Firm Wide Risk Assessment) in recent months.
- Don’t forget that completing the questionnaire is a regulatory requirement – failure to complete it is likely to result in regulatory action.