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 (MLR) having to take part, it will apply to all firms, as it includes questions about the sanctions regime (which applies to all firms, whether in or out of scope of the MLR) and in the SRA’s Questions and answers section it specifically states that firms out of scope must still complete the questionnaire!
The digital questionnaire will be sent to the firm’s COLP in the first week of July, and the online portal, through which the data must be submitted, will be open “during July” so work on the basis that the deadline will be the end of July.
Preparation tips
- Look at the specimen questionnaire (and dig out last year’s answers) and start collecting the information you will need asap – July is not far away and there are 44 questions, quite a lot of which involve statistics, which may take some time to collate.
- Ensure your firm wide risk assessment and policies & procedures (in relation to AML and Sanctions) are up to date and tailored to your firm (including considering TCSP risks). The questionnaire asks when you last updated these, so if it was some time ago/ well before recent updates, e.g. to the LSAG guidance/ longer ago than the documents state you will review them, now is the time to get on to that! (And don’t forget to keep previous versions in a safe place).
- Ensure your AML training is up to date (at least annual training is expected) and you have clear records of this.
Please do reach out if you have any questions about the questionnaire or require any help with updating your policies and procedures.