Today’s Conveyancer – The SRA AML Report – what does it mean and what can you do about it?
Amidst a tide of new and updated legal anti-money laundering (AML) regulation, conveyancing remains very much the highest risk area.
As part of this, failure to carry out Source of Funds (SoF) checks remains the second most common reason for an AML report to be received from the regulator. From the SRA report:
“Understanding the source of funds is crucial to understanding the risk of the transaction. While several firms were able to provide an explanation of the enquiries they made, on a large proportion of files there was no audit trail.”
Although forming a key data point for the evidence, a full and effective SoF check isn’t just about bank statements. It’s not even just about any technology used to effectively collect relevant data. At its heart, a SoF check is about understanding your client properly to come to the best decision within your risk parameters and then practically being able to evidence your methodology. If and when an internal or regulator review comes around, it’s critical to be able to explain the rationale and provide an audit trail to back it up.
Read more about the SRA AML report and how to combat money-laundering here.