UK Releases Report on AML, Sanctions Compliance
The U.K. Solicitors Regulation Authority released its annual Anti-Money Laundering report for 2022-23, covering the agency's role in addressing money laundering and terrorism financing, the role of private parties, enforcement activity, how to report suspicious activity, sanctions, case studies and risk assessments.
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Among the report's findings was that around 26% of the industry's AML policies reviewed by the SRA "failed to mention what steps a fee earner should take to make sure their client is not subject to financial sanctions." While this doesn't "necessarily need to be included in an AML policy, firms should record their approach to complying with sanctions somewhere in writing," the report said.
The agency noted the actions it took in response to Russia's invasion of Ukraine, including reviews of 23 high-risk firms, reviews of firms' sanctions compliance approaches, the publication of sanctions guidance and exercises requiring over 3,000 law firms to provide the agency with information on how they approach financial sanctions risk. The report released a summary of this exercise.