Anti Money Laundering Compliance Service

Over the past 12 months, supervisors have imposed a range of sanctions and corrective measures upon firms, including but not limited to fines for both the businesses and individuals, letters of advice, reprimands, warnings and, in some cases, conditions have been placed upon a firm’s authorisation.

At Crowe, our team have been helping clients with their AML audits for over 12 years. We provide guidance and auditing services across a range of sectors, undertaking reviews and testing of policies and procedures, reporting findings and providing recommendations to support your firm’s policies while maintaining the requirements of the legislation and your AML supervisor.

Section 21 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations (MLRs 2017) requires a firm to implement internal controls. It requires, where appropriate with regard to the size and nature of its business, firms to establish an independent audit function with the responsibility to:

• examine and evaluate the adequacy and effectiveness of the firms’ policies, controls and procedures to ensure that they comply with the requirements of the MLRs 2017
• make recommendations in relation to those policies and procedures
• monitor the firm’s implementation and compliance with those recommendations.

Firms can undertake their own internal audit, however, the person undertaking the audit should not be involved in writing the firm’s policies or be involved in the day-to-day operation of the AML function, gathering of customer due diligence, etc. The individual should also be familiar with the requirements of the MLRs 2017 and associated legislation, sector guidance and be sufficiently senior within the firm so that the board will undertake a comprehensive review of the findings and implement recommendations where required/appropriate.

An independent review/GAP analysis of your firm's processes and procedures, measured against the legal requirements of MRLs 2017, associated legislation and industry sector guidance. We present our findings with a traffic light system, detailing any deficiencies, if found, and providing our recommendations for an AML-compliant programme for the following areas.

• Governance framework.
• Risk assessment.
• Policies and procedures.
• Know your client/customer due diligence.
• Personnel/screening training.
• Suspicious activity reports.
• Data retention.
• Interviews with key personnel.
• Testing.
  

With regulators ramping up their activity on monitoring for AML non-compliance, now is the time to make sure your organisation has the right controls, procedures and processes in place.

Impact on law firms

Recently, the Solicitors Regulations Authority (SRA) handed out its biggest fine of £25,000 – the maximum that can be imposed. Data analysis carried out by an independent client due diligence platform Thirdfort found that smaller law firms are more likely to come under SRA scrutiny. This is most likely because there is a lack of in-house resources and specialism in AML at the law firm.

Impact of financial institutes

The Financial Conduct Authority (FCA) has in recent years begun to take a more robust stance on AML inspections. Most notably, they issued a fine of £107.7 million to Santander in 2022 for serious and persistent gaps in its AML controls, which affected Business Banking customers between December 2012 and October 2017, and a fine of £28.96 million to Starling Bank in 2024, for significant failings in its financial crime systems and controls, particularly related to financial screening sanctions.

We work closely with you to understand your requirements before tailoring our costs depending on the nature and size of your business.

Related areas:

• Corporate Finance
• Financial Crime
• Financial Services
• Professional Practices