Webinar on SRA's AML and Financial Sanctions Questionnaire

Introduction

Topic: SRA's Questionnaire on firms' AML and financial sanctions position.
Notification: Email notifications have been sent, check junk mail if not received.
Key Dates: The window for firms to complete the form is from 8 August to 23 September 2024.
Importance: Submissions are mandatory and answers must be accurate to avoid regulatory issues.
Objective: Review sample questions and practical preparation tips.

Regulator: SRA (Solicitors Regulation Authority) under OPBAS oversight.
Approach: Risk-based approach will inform the SRA's resource allocation and reviews.
Purpose: Data collection to guide SRA in their own audits and reviews.
Submission: Through SRA portal using MySRA login; must be completed by MLRO/MLCO/COLP.
Preparation: Coordination between accounts, compliance, and HR teams might be necessary.

Activities in Scope: Yes/No questions on regulated activities and company services.
Suspicious Activity Reports (SAR): Number of reports to NCA in the last 12 months (ranges provided).

Firm Risk Assessment: Update status and policies, controls, and procedures (PCPs).
Employee Training: When last updated; refreshing training suggested if over a year old.
Client and Financial Data: Percentage of matters and fee earners under money laundering regulations, largest money deposit, enhanced due diligence cases, politically exposed persons.

Relevance: Only for firms providing TCSP.
Turnover Percentage: Estimates for different TCSP activities.
Risk Assessment: Inclusion in firmwide risk assessment and mitigation steps taken.

SAR Breakdown: Types of reports (DAMLs, information-only) and areas involved (TCSP, real property, other regulated areas).
Non-Regulated Services: Reporting outside AML scope (e.g., litigation, wills).

Risk Assessment in Writing: Sanctions risks documentation in firmwide risk assessment.
Client Connections to High-Risk Countries: Yes/No for listed countries.
Services Provided: Areas like trade, shipping, aviation, finance, etc.
Sanctions Checks: Procedures for new and existing clients, frequency, ongoing monitoring.
Frozen Assets: Whether holding any, total amount, number of clients, reports made to OFSI.

Sanctions Checks: Relevant for all clients, regardless of AML scope; counterparties based on risk profile.
Proliferation Financing: Include in risk assessment even if unlikely to apply; templates available for guidance.
Insurers and Questionnaires: Unlikely to request full questionnaire in PII renewals; might ask specific high-risk questions.
Preparation: Review and update firmwide risk assessments, PCPs, and training before submission.

Resources: Sample questions available on SRA website although the portal is now open where questions can be reviewed https://www.sra.org.uk/sra/news/firm-anti-money-laundering-sanctions-data-requirements/
Support: HiveRisk are available to provide assistance review and repair of PCPs, firm wide training, and independent (R21) audits.
Future Sessions: Another webinar planned for 29th August 2024 focused on Q&A.
Additional Resources: Free webinars on related topics available on the HiveRisk.com website.

Contact: For complimentary Proliferation Finance Risk Assessment template or further assistance, get in touch with [email protected]