Independent AML Audits for Law Firms - Common Failures & Practical Lessons

Introduction

Law firms invest considerable time in preparing AML policies, procedures and risk assessments. However, an independent audit does not consider documentation in isolation: it examines whether the firm’s controls are appropriate, understood and operating effectively in practice.

Recurring weaknesses often arise from a gap between a firm’s written procedures and what happens on individual matters. Problems involving matter risk assessments, source-of-funds enquiries, ongoing monitoring, supervision and record-keeping can expose a firm to regulatory criticism even where its policies appear comprehensive.

In this new virtual classroom seminar, Tracy Thompson, an experienced independent AML auditor working with more than 100 law firms annually, will share anonymised insights into the weaknesses she commonly identifies. Rather than providing a general update on the AML regulations, the session will focus on how compliance arrangements are tested, why apparently compliant systems fail effectiveness reviews and what firms can do in response.

The session will help firms assess their own arrangements through the eyes of an independent auditor and take proportionate action before weaknesses attract regulatory attention.

What You Will Learn

This live and interactive session will cover the following:

• When an independent AML audit function is appropriate under Regulation 21
• What independent AML auditors examine and test in practice
• Common weaknesses identified across SRA-regulated law firms
• Identifying gaps between written procedures and day-to-day practice
• Why firm-wide and matter-level risk assessments fail effectiveness reviews
• Recurring problems with client due diligence and source-of-funds enquiries
• Weaknesses in ongoing monitoring, supervision and record-keeping
• Assessing whether AML policies and controls are understood and embedded
• Responding to audit findings and prioritising remedial action
• Recording improvements and creating a defensible compliance trail
• Practical steps to strengthen AML controls proportionately

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.