AML Audits

AML Audit Approach

Our approach to AML audits is based on decades of experience as to what really makes a difference in achieving compliance. This deep expertise, coupled with the most up to date sector knowledge, gives you the highest level of assurance that you’re getting AML right. Our service comprises a health check of your firm’s approach to risk, its policies, procedures and controls as well as your training programme.

We will work with you to determine the appropriate level for the number of file inspections we undertake, to enable you to reach the requisite level of reassurance as to your controls. You will receive a thorough report and recommendations based on the regulations, guidance and best practice.

AML Audit Team

Our AML audit team is led by Colette Best (former director of AML policy at the SRA). Colette established the AML directorate at the SRA in 2019 and led it until she joined Kingsley Napley in 2024. Colette has a background in AML policy and supervision, including leading on the implementation of the third money laundering directive for the RICS in 2006, and working with mortgage lenders at the Building Societies Association and investments at the Association of British Insurers. Colette has a detailed knowledge of both the money laundering regulations, and a unique insight into the regulatory approach and guidance by the SRA.

Why an audit from AML Assure?

Commissioning an Anti-Money Laundering (AML) audit from AML Assure will go a long way to protect your firm against allegations of breaches of the regulations and make sure you are prepared for an Solicitors Regulation Authority (SRA) inspection.

AML audits are bespoke to large law firms that are required to undertake regular independent audits to ensure their compliance with the regulations, and who may not be able to source an appropriate audit which meets their needs. The SRA has made it clear that is expects most firms undertaking work in scope of the regulations to have such an audit.

We recognise the unique challenges to large law firms in AML compliance, managing issues such as centralised customer due diligence, sophisticated clients and complex work. We have the experience and resources to guide you through any issues we identify and any changes you wish to make as result of an AML audit or changes to regulations.

What the AML Assure audit includes

An AML Assure audit includes the following:

• A thorough desk-based review of your AML control framework. As part of this we review your firm-wide risk assessment to ensure that it meets the requirements in the regulations and is appropriate to a firm of your size and nature. We review your policies, procedures and controls to ensure that they meet the regulatory requirements and are in line with the risks you have identified in your firm-wide risk assessment. We also undertake a best practice assessment of your policies, procedures and controls to signpost where you may wish to make changes to bring you in line with the Legal Sector Affinity Group (LSAG) guidance and expectations of the regulator. A review of your training programme and training records to establish whether your training programme is in line with the expectations of the regulator. A review of your client/matter risk assessment template, if you use one, to check whether it is line with the requirements in the regulations, and to provide a steer on whether you are assessing risk on clients and matters in an effective and proportionate way.
• An onsite audit where we will meet with key personnel in your firm. This will include an initial meeting with the money laundering reporting officer (MLRO) and money laundering compliance officer (MLCO) to further discuss your controls and any areas of concern. We will interview a number of fee earners to establish how your training, controls and due diligence is being used in practice.
• We will undertake a series of files reviews onsite. As part of the audit we will use a bespoke statistical approach to determine an appropriate sample size given a desired level of precision, confidence level and estimated proportion of the population. The file reviews will check whether your controls are being applied on files as expected and that risk assessments, customer due diligence, source of funds checks and ongoing monitoring are being undertaken appropriately.
• Following the on-site audit, we will review all of the information and issue you with a report. This will set out any recommendations to ensure compliance with the money laundering regulations, and any suggestions for changes to bring you into line with guidance or industry best practice. Where necessary, we will schedule a follow-up within an agreed timetable to discuss the implementation of any recommendations. This is to fulfil requirement 21(1)(c)(iii) of the money laundering regulations which states that audits must include an element of monitoring the implementation of recommendations.

What our AML Audit will give you

The focus of our audits is to go beyond ticking the box of the required audit under r21 of the money laundering regulations. Our AML audit will ensure you are well placed to undergo an onsite inspection or desk-based review by the regulatory. You will receive an audit that assesses not just compliance with the regulations, but goes further to provide advice on the appropriateness of your controls and benchmarking against other similar firms. Our audits are designed to help you manage risk in a way that fits your business and commercial needs. You will receive a clear and comprehensive report which will help you implement necessary changes and help you decide whether there are any best practice adjustments that you wish to make. We can also help with communicating the audit finding and recommended next steps to boards.