The Solicitors Regulation Authority (SRA) has published a thematic review focused on anti-money laundering (AML) training in law firms. This review is a timely reminder that training plays a significant part in regulatory compliance and risk management within firms.
As the SRA steps up its AML audit function, firms can expect training to become a key focus in future visits. Understanding the SRA’s expectations now will help firms prepare for more thorough scrutiny in the future. Here’s what the thematic review means for your firm.
AML training – What the SRA thinks ‘good’ looks like
The SRA reviewed the AML training practices of selected firms, assessing both content and delivery methods. Their findings underscore a clear message: they do not consider AML training to be a one-size-fits-all exercise but should be tailored to reflect the specific risks and services of each firm. To satisfy the regulator, firms must ensure that:
- Training content is relevant: AML training should go beyond basic knowledge, diving into the specific risks relevant to the firm’s practice areas, client profiles, and geography. The SRA expects firms to cover the latest legislative changes, risk indicators, and practical guidance on identifying and reporting suspicious activity. Content and delivery should be informed by the firm-wide risk assessment.
- Training frequency is adequate: The review points out that ongoing training is critical. For firms in high-risk sectors, annual or even semi-annual training may be necessary to ensure teams are equipped to recognise emerging risks. The Money Laundering Regulations 2017 (MLRs) require regular AML training for all relevant staff, ensuring knowledge stays current and risks are managed proactively.
- Engagement and comprehension are assessed: It’s not enough to simply deliver AML training. Firms are expected to evaluate the understanding and application of AML principles in practice. The SRA’s report emphasises that comprehension assessments—such as quizzes, case studies, or scenario-based discussions—should be embedded in training sessions to ensure that staff can apply what they’ve learned.
- Training is documented and demonstrable: The SRA’s checklist highlights the importance of maintaining accurate training records. These records should reflect each employee’s training history, with clear dates and topics covered, to demonstrate compliance if inspected. Documentation can be crucial evidence that a firm takes its AML responsibilities seriously.
What’s New? The SRA’s AML Training Checklist
To support firms, the SRA has released an AML Training Checklist. This checklist serves as a practical tool for firms to assess their AML training programs, addressing relevance, frequency, evaluation and documentation.
This checklist can be a helpful starting point for firms reviewing their AML training approach, particularly as the SRA continues to scale its AML audits.
Regulatory Responsibility and Increasing Audits
AML training is more than just a good practice; it’s a regulatory requirement under Regulation 24 of the Money Laundering Regulations 2017. Alongside AML risk assessments and policies, training must be prioritised within firms as part of their compliance obligations. The SRA’s focus on AML training in its thematic review reflects the regulator’s commitment to increasing the breadth and depth of its audit function. Firms should anticipate more SRA visits, with AML training forming a core component of future reviews. This shift is particularly important in today’s regulatory climate, where failure to meet AML obligations can lead to significant penalties.
The implication is that all AML training must be recorded.
For firms looking to improve their AML training program and meet the SRA’s expectations, our tailored AML Training Services can provide specialised, up-to-date sessions designed to address both foundational knowledge and complex, firm-specific risks.
