Following a report issued by the Office of Professional Body Anti-Money Laundering Supervision (OPBAS) in March 2019 regarding the standard of supervision across the UK’s professional bodies, we have seen a marked increase in the level of scrutiny placed on Designated Non-Financial Businesses and Professions (DNFBPs) in relation to their compliance with the Money Laundering Regulations 2017.
By example, the Solicitors Regulation Authority (SRA) published the results of a review conducted across 59 law firms on the 7th May 2019 which concluded “that a significant minority of law firms are not doing enough to prevent money laundering, with some falling seriously short”. As a result of the review the SRA put 26 firms into its disciplinary processes.
Conclusion
In order to ensure compliance with the Money Laundering Regulations 2017, law firms and other DNFBPs must ensure that they have a robust financial crime control framework in place, including an approach and methodology to undertake practice-wide money laundering and terrorist financing risk assessments, considering the risks posed at a minimum by the firm’s clients, geographic areas of operation, products and services, transactions, and delivery channels.