AML (Anti-Money Laundering) Audit Services for Law Firms

Our clients have told us time and again that our audit reports are the most detailed, but easy to digest, that they have ever received.

We start by reviewing your documented controls and records that support AML controls and provide you with a written Gap Analysis Report.

We don’t simply review an AML policy. Like dropping a stone into a pond, your AML controls touch upon many others. And so, we review a host of supporting documents and records as well, including;

• The Practice/Firm-Wide AML Risk Assessment
• The policy for staff training on AML
• Staff training records
• Supervision procedures
• File review procedures
• Reporting and monitoring procedures
• MLRO reports
• Matter file forms for recording outcomes of AML checks
• Reviews of EID/V service providers

We are unique in the sector by sending you an interim written report after the desktop portion of the audit, rather than making you wait until after the onsite visit!

And, we conduct a conversation with you to consider the findings so far.

This provides the opportunity to pinpoint any particular aspects of concern that the firm might like for us to drill into when we conduct the onsite portion of the audit.

Then, we prepare the visit plan to share with you in advance of the visit.

After the desktop review has been completed, we follow up with a visit to your offices to examine the controls in action.

The list of aspects that we examine is long and thorough, and includes;

• Meeting with supervisors, Heads of Department, the MLRO and others in responsible roles
• Conducting file reviews to examine the conduct of AML controls in the ‘real world’
• Viewing the operation of the case management system controls for AML
• Perusing the AML forms on matter files
• Examination of the training records and training programme that supports AML controls
• Examination of the risk register
• Examination of the register of breaches, near misses and the regular reviews of risk data
• Reviewing historical file review findings/trends
• Meeting with fee earners and support staff to understand their perspective and to test their application and experience of controls

At the end of the visit, we meet with the MLRO and compliance managers to provide immediate feedback and to discuss any immediate concerns.

We add our findings from onsite to the Gap Analysis Report to provide you with a written narrative as to where your practice stands with its AML controls and next steps to resolve the gaps.

There is no 'pass' or 'fail’ where the audits are concerned. Instead, we apply colour coding to each of the remarks in our report, to provide at-a-glance navigation as to the suggested prioritisation that the Firm might apply to addressing each concern.

We endeavour to provide as much value as possible by providing you with plain language feedback and explanations of concerns to be addressed. This means that our reports typically run to a sector-leading 30+ pages.

After your having read the report, and if you wish, we conduct a final conversation with you to chat through any points raised in the report.

A review of the Firm’s progress in taking action on the guidance provided following the Audit; usually 3 to 6 months after Stage 6.

We ask the Firm to provide us with copies of documentary evidence of the progress that it has made towards addressing the issues.

Then we conduct a remote meeting, either by MS Teams or telephone, to provide our feedback and discuss any aspect of the issues.

Finally, we follow-up with a written summary by way of our independently documenting the Firm’s progress and to summarise any further guidance.