Time to update your firm wide risk assessment (FWRA)
All law firms caught by the Money Laundering Regulations must have a firmwide risk assessment (FWRA).
FWRAs are the backbone of money laundering compliance. They inform compliance officers where they need to focus policies, training and client due diligence.
In a recent live Zoom training, Rachael Eyre and Jonathon Bray led a session on how to update your law firm’s FWRA.
The slides and recording are available in the Webinar section, below.
In this post we list the main points to come out of the live training.
How to comply with the SRA Transparency Rules
Samantha Bray discusses the SRA Transparency Rules and the lessons learned reviewing hundreds of law firm websites.
Just before Christmas, the SRA sent out a considerable number of letters to law firms with ‘non-compliant’ websites.
Some firms were caught out on minor technicalities. You might argue that the regulator is being overly picky (especially in an age of supposedly principles based regulation), and on occasion goes beyond the letter of the rules.
Even so, it is sensible to review your own compliance to avoid unwanted SRA attention.
In the post:
- the Top 5 most common Transparency Rules breaches
- compliance tips
- free template checklist for reviewing your own firm’s website
The Top 10 Compliance Topics of 2021
This free COLP resource is an overview of December’s monthly compliance webinar from the Jonathon Bray team. Sign up to our newsletter for invitations to future events.
We called it “The Final Count Down” of 2021’s hot compliance issues. Here are the 10:
- AML
- Client money and using the client account as a banking facility
- Undertakings
- PII
- Junior lawyer strike-offs
- Access to legal services
- Equality, diversity and inclusion
- Covid-19
- NDAs and sexual misconduct
- Cyber risks
News and Guidance
Law Society Updates
SRA Updates
- Guidance – Advising on leasehold provisions including ground rent clauses
- Resource – AML guidance and support – a useful, if hard to find, summary of where to find different guidance notes on specific areas of money laundering regulation.
Webinars
This month’s live webinar session was ‘Time to update your firm wide risk assessment’ (see post above).
To access the recording please follow this link and use passcode F!+M6XyE. Access expires in 30 days.
The slides have been uploaded to SlideShare:
Disciplinary decisions
- Paul Ross – non-qualified property fee earner ‘struck off’ (Section 43 Order) for backdating documents and misleading clients to give the impression of progress on a file.
- Siu Yung Alan Ma and Taut-Yang Cheung – partners fined £7,500 each (with practising conditions) for permitting a non-lawyer unsupervised conduct of a significant group litigation.
- Julia Cooper – solicitor struck off for exploiting a vulnerable client by facilitating the sale of the client’s property to her own civil partner at a £250,000 discount.
- Tapfumanei Nyawanza – fined £12,500 for incompetence, working on a client’s immigration case for two years before realising it had been struck out.
- Alan Martyn Grant – rebuked for drink driving offence.
- Rajinder Kumar Puri – struck off for misleading the SRA (by creating false documentation) and practising without PII for over two years.
- Javaid Iqbal Wattoo – fined £2,000 for failing to co-operate with an SRA investigation.
- Richard Gregory Barca – rebuked for failing to return client money after clients withdrew instructions.
- Nicola Phillips Solicitors LLP (a firm) – fined £4,000 for various Accounts Rules breaches, including failing to keep proper accounting records and conduct client account reconciliations.
- Mohamed Faliq Mohamed Ismail – struck off following a conviction for possessing and distributing indecent images of children.
- Afshan Manzoor – fined £2,000 for using the client account as a banking facility, distributing £20,000 surplus funds to an unconnected third party by way of loan.
